Privacy Policy

This Privacy Notice for Palance (‘Palance’, ‘we’, ‘us’, or ‘our’) describes how and why we might access, collect, store, use, and/or share (‘process’) your personal information when you use our services (‘Services’). Palance is currently a pre-incorporation project; details of the formal operating entity and registered contact address will be published when confirmed.

• Visit our website at https://palance.co or any website of ours that links to this Privacy Notice.
• Use Palance. We provide a multi-asset portfolio analytics platform designed to help investors understand the performance, composition, and risk of their holdings across brokerages and asset classes. Our Services include data visualisations, AI-generated insights, and analytics intended to support users in evaluating their portfolios. We may also offer optional features such as brokerage or account connection and portfolio import. All insights and analytics are provided for informational purposes only and should not be considered financial, investment, or trading advice.
• Engage with us in other related ways, including any sales, marketing, or events.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@palance.co.

Summary of key points

This summary provides key points from our Privacy Notice, but you can find more details on any topic using the table of contents below.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties.

How do we keep your information safe? We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission or storage technology can be guaranteed to be 100% secure.

What are your rights? Depending on where you are located, applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way is by contacting us at info@palance.co. We will consider and act upon any request in accordance with applicable data protection laws.

Table of contents

1. 1. What information do we collect?
2. 2. How do we process your information?
3. 3. What legal bases do we rely on?
4. 4. When and with whom do we share your information?
5. 5. Do we use cookies and other tracking technologies?
6. 6. Do we offer artificial intelligence-based products?
7. 7. How do we handle your social logins?
8. 8. How long do we keep your information?
9. 9. How do we keep your information safe?
10. 10. Do we collect information from minors?
11. 11. What are your privacy rights?
12. 12. Controls for do-not-track features
13. 13. Do United States residents have specific rights?
14. 14. Do we make updates to this notice?
15. 15. How can you contact us about this notice?
16. 16. How can you review, update, or delete your data?

1. What information do we collect?

Personal information you disclose to us

In short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide when you register on the Services, express an interest in obtaining information about us or our products and Services, participate in activities on the Services, or otherwise contact us. The personal information we collect may include:

• email addresses;
• connected brokerage or custodian account identifiers and metadata (e.g., read-only API credentials or connection tokens);
• manually entered or imported portfolio holdings and transactions;
• risk preferences or investment profile (if applicable);
• linked social profile information (if you choose to use social login);
• information you provide when contacting support or completing feedback forms;
• password (only if you create an account with email and password; stored securely using encryption);
• payment information (e.g., credit/debit card details) entered after any free trial period. This is processed by our third-party payment processor; we do not store card details on our servers;
• any additional information you provide through support or feedback.

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number and associated security code. All payment data is handled and stored by Stripe. You may review their privacy notice at https://stripe.com/privacy.

Social Media Login Data. We may provide you with the option to register using your existing social media account details. If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in ‘How do we handle your social logins?’ below.

All personal information that you provide must be true, complete, and accurate, and you must notify us of any changes to such information.

Information automatically collected

In short: Some information, such as your IP address and/or browser and device characteristics, is collected automatically when you visit our Services.

This information does not reveal your specific identity but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, and information about how and when you use our Services. It is primarily needed to maintain the security and operation of our Services, and for internal analytics and reporting. Like many businesses, we also collect information through cookies and similar technologies. The information we collect includes log and usage data, device data, and location data.

2. How do we process your information?

In short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information for a variety of reasons, including to: facilitate account creation and authentication and manage user accounts; deliver and facilitate delivery of services; respond to user inquiries and offer support; send administrative information; fulfil and manage your orders and payments; enable user-to-user communications where offered; request feedback; send you marketing and promotional communications (in accordance with your preferences); protect our Services, including fraud monitoring and prevention; identify usage trends; determine the effectiveness of our marketing; and save or protect an individual’s vital interests. We may also process your information for other purposes with your prior explicit consent.

3. What legal bases do we rely on to process your information?

In short: We only process your personal information when we have a valid legal reason to do so under applicable law.

If you are located in the EU or UK, the GDPR and UK GDPR require us to explain the valid legal bases we rely on. These may include: Consent (which you can withdraw at any time); Performance of a Contract; Legitimate Interests (e.g., to analyse how our Services are used so we can improve them, support our marketing, and prevent fraud, where those interests do not outweigh your rights); Legal Obligations; and Vital Interests.

If you are located in Canada, we may process your information where you have given express or implied consent. In some exceptional cases we may be legally permitted to process your information without your consent, for example for fraud detection and prevention, or where required to comply with a subpoena, warrant, or court order.

4. When and with whom do we share your personal information?

In short: We may share information in specific situations and/or with the following categories of third parties.

We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us and require access to do that work. We have contracts in place designed to safeguard your personal information. The categories of third parties we may share personal information with include: data analytics services; data storage and cloud computing providers; AI platforms; payment processors; product engineering and design tools; sales and marketing tools; user authentication services; website hosting providers; performance monitoring tools; communication and collaboration tools; and finance and accounting tools.

We may also share your personal information in connection with a business transfer (e.g., a merger, financing, or acquisition), or with our affiliates, in which case we will require those affiliates to honour this Privacy Notice.

5. Do we use cookies and other tracking technologies?

In short: We may use cookies and similar technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some help us maintain security, prevent crashes, fix bugs, save your preferences, and assist with basic site functions. We may also permit third parties to use tracking technologies for analytics and advertising. You can manage or withdraw consent for cookies at any time through your browser settings or the cookie consent tools available on our website. We may share your information with Google Analytics to track and analyse the use of the Services; you can opt out via Google’s opt-out tool.

6. Do we offer artificial intelligence-based products?

In short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (‘AI Products’).

We provide our AI Products through third-party AI service providers, including Google Cloud AI. Your input, output, and personal information may be shared with and processed by these providers to enable your use of our AI Products for the purposes described in this Notice. Our AI Products are designed to generate portfolio insights and analytics. All personal information processed using our AI Products is handled in line with this Privacy Notice and our agreements with those providers.

7. How do we handle your social logins?

In short: If you choose to register or log in using a social media account, we may have access to certain information about you.

Where you register or log in using a third-party social media account, we will receive certain profile information from your provider (which may include your name, email address, and profile picture). We will use it only for the purposes described in this Privacy Notice. We do not control, and are not responsible for, other uses of your personal information by your third-party social media provider.

8. How long do we keep your information?

In short: We keep your information for as long as necessary to fulfil the purposes outlined in this Notice unless otherwise required by law.

No purpose in this Notice will require us keeping your personal information for longer than twelve (12) months past the termination of the user’s account, unless a longer retention period is required or permitted by law. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it, or securely store and isolate it from further processing until deletion is possible.

9. How do we keep your information safe?

In short: We aim to protect your personal information through organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that unauthorised third parties will never defeat our security. Transmission of personal information to and from our Services is at your own risk; you should only access the Services within a secure environment.

10. Do we collect information from minors?

In short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18. If we learn that personal information from users under 18 has been collected, we will deactivate the account and take reasonable measures to promptly delete such data. If you become aware of any data we may have collected from children under 18, please contact us at info@palance.co.

11. What are your privacy rights?

In short: Depending on your location, you may have rights that allow greater access to and control over your personal information.

In some regions (like the EEA, UK, Switzerland, and Canada) you have certain rights under applicable data protection law. These may include the right to request access to and obtain a copy of your personal information, to request rectification or erasure, to restrict processing, to data portability, and not to be subject to automated decision-making. You may make such a request by contacting us at info@palance.co. If you are located in the EEA or UK and believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection authority.

Withdrawing your consent. If we are relying on your consent, you have the right to withdraw it at any time by contacting us. This will not affect the lawfulness of processing before its withdrawal.

Account information. To review or change your account information, log in to your account settings. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases, though we may retain some information to prevent fraud, troubleshoot problems, assist investigations, enforce our legal terms, and/or comply with applicable legal requirements.

12. Controls for do-not-track features

Most web browsers include a Do-Not-Track (‘DNT’) feature you can activate. As no uniform technology standard for recognising DNT signals has been finalised, we do not currently respond to DNT browser signals. If a standard is adopted that we must follow in the future, we will inform you in a revised version of this Notice.

13. Do United States residents have specific privacy rights?

In short: If you are a resident of certain US states, you may have the right to request access to, correct, obtain a copy of, or delete your personal information, and to opt out of certain processing.

Depending on your state of residence, you may have rights including the right to know whether we are processing your personal data, to access and correct it, to request deletion, to obtain a copy, to non-discrimination for exercising your rights, and to opt out of processing for targeted advertising, the sale of personal data, or certain profiling. We have not sold or shared personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. To exercise these rights, contact us at info@palance.co. If we decline to take action, you may appeal by emailing the same address.

14. Do we make updates to this notice?

In short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

The updated version will be indicated by an updated date at the top of this Privacy Notice. If we make material changes, we may notify you either by prominently posting a notice or by directly sending you a notification. We encourage you to review this Privacy Notice frequently.

15. How can you contact us about this notice?

If you have questions or comments about this notice, you may email Palance at info@palance.co. A formal postal contact address will be published when the operating entity is confirmed.

16. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country or US state of residence, you may have the right to request access to the personal information we collect from you, details about how we have processed it, to correct inaccuracies, or to delete your personal information. You may also have the right to withdraw your consent. To make such a request, please contact us at info@palance.co.