Legal · Privacy

Privacy Policy

Last updated · August 2026

§01

Introduction

ALAN Global Intelligence ("ALAN," "we," "us," or "our") respects your privacy and is committed to protecting it. The following Privacy Policy explains how we collect, use, disclose, retain and protect information when you: Visit alanglobalintelligence.com or other ALAN websites; Create or access an ALAN account; Subscribe to or use the retail platform, the ALAN Terminal, or the commercial Global Intelligence Dashboard; Use ALAN data feeds, analytics, research, or tools; or Communicate with us.

This Privacy Policy applies to information collected through our websites and platform services covering both the individual categories of information we collect as well as the aggregation of all or some of the individual categories of information. This policy does not govern the contractual relationship between ALAN and its commercial or enterprise clients, which is governed by the applicable Enterprise Agreement and any associated data processing agreement. It should be read together with our Terms of Service and any action related to Privacy that is not covered in this document is controlled by the Terms of Service. Different data practices may apply depending on the nature of your interaction (for example, a website visitor, a retail subscriber, or an authorized user of an enterprise deployment).

§02

Categories of Information We Collect

Information you provide directly may include:

Name
Email address
Phone number
Organization, firm, or entity name
Billing and payment information (processed by our payment providers)
Account credentials
Communications with ALAN and support requests
Content and inputs you submit to the Services, such as watchlists, saved portfolios, holdings, notes, scenario inputs, and saved analyses

Usage and technical information may include:

IP address
Browser type and device identifiers
Operating system
Referring URLs
Pages and features accessed
Date and time of access
Usage, session, and diagnostic data

Account and platform information may include:

Account activity and login records
System and audit logs
Subscription tier and billing status
Deployment and configuration settings
Support interactions

§03

Sources of Information

We may collect information:

Directly from you
Automatically through your use of our websites and Services
From enterprise clients and authorized users where you access the Services through an organization's account
From service providers, payment processors, and infrastructure vendors that support our operations
From public, government, and third-party data sources that power the Services (see Section 4)

§04

Public and Third-Party Data Within the Services

The Services incorporate and analyze data from public, government, and third-party sources, which may include SEC EDGAR filings, OFAC and other sanctions lists, the Federal Register, congressional and government financial-disclosure records, corporate insider (Form 4) filings, institutional holdings (Form 13F) data, maritime (AIS) and aviation (ADS-B) signals, and similar feeds.

Some of this information references identifiable individuals, for example, corporate insiders, public officials, or fund managers. We process this information to provide intelligence, research, and analytics features, and it is generally drawn from publicly available sources or records made lawfully available by government entities. We use it for the purpose of operating the Services and not to build independent consumer-marketing profiles.

ALAN does not create or maintain independent consumer-marketing databases, and ALAN does not sell or license this data to third parties for their own marketing purposes. Where applicable law affords rights with respect to such information, we will honor those rights to the extent required (see Sections 17-18). Third-party and government sources are subject to their own terms, methodologies, and limitations, and we do not warrant their accuracy or completeness.

§05

Service Provider / Processor Role for Enterprise Clients

When ALAN provides the Services to a commercial or enterprise client, ALAN may process certain information on the client's instructions and for the purpose of delivering the Services described in the applicable Enterprise Agreement. In those circumstances, the client is responsible for the lawfulness of the data and instructions it provides, and the client's own privacy notices govern its relationship with its personnel and end users. ALAN does not independently determine the purposes of client-provided data beyond providing the Services and improving and securing them as permitted.

§06

How We Use Information

We may use collected information to:

Operate, maintain, and secure our websites and Services
Provide, personalize, and improve the Services and user experience
Manage user accounts and authentication
Process billing, subscriptions, and transactions
Respond to support inquiries and communicate with you about the Services
Send you product updates, newsletters, or marketing communications (from which you may opt out)
Monitor performance, detect and prevent fraud, abuse, and unauthorized access
Enforce our agreements and policies
Comply with legal, regulatory, licensing, and audit obligations

§07

Cookies and Similar Technologies

We may use cookies and similar technologies to operate, secure, and measure our websites and Services, including to maintain sessions, recognize returning users, support functionality and security, and analyze usage and performance. We use Plausible, a cookieless analytics service; no advertising trackers, no cross-site cookies. Most web browsers allow you to control cookies through browser settings. If cookies are disabled, some parts of the websites or Services may not function properly. ALAN does not use cookies to build cross-site advertising profiles for third-party marketing. We respond to “Do Not Track” (DNT) signals as follows: because we do not track you across third-party websites over time and do not use cross-context behavioral advertising, our websites do not behave differently when a DNT signal is present, and we do not authorize any third party to collect personally identifiable information about your activities across different websites through the Services.

§08

How We Share Information

We may disclose information:

To service providers and sub-processors that support our operations (including cloud hosting, payment processing, analytics, and customer support)
To enterprise clients and their authorized users where you access the Services through an organization's account
In connection with a merger, acquisition, financing, or other corporate transaction
To comply with legal obligations, lawful requests, or regulatory or licensing requirements
To protect the rights, property, or safety of ALAN, our users, or others
With your consent or at your direction

We may also disclose aggregated or de-identified information that does not identify any individual. Third-party platforms and providers may maintain their own privacy policies governing their handling of information.

§09

Enterprise and Air-Gapped Deployments

For self-hosted, on-premises, or air-gapped deployments of the Global Intelligence Dashboard, the customer controls the operating environment and the data within it. In these deployments ALAN may receive little or no personal information, and in fully air-gapped installations ALAN may receive none. Where ALAN processes personal data on a client's behalf, that processing is governed by the applicable Enterprise Agreement and any associated data processing agreement, which control over this Privacy Policy as to that processing.

§10

ALAN Echo Desktop Application (On-Device Processing)

ALAN Echo desktop app. Echo is designed so your voice data never leaves your device: dictation audio is captured from your microphone, transcribed locally by an on-device model, and the audio is discarded. We do not receive, store, or have any ability to access your audio, transcripts, or dictation content, and the app contains no analytics or telemetry.

What the app does transmit: (1) when you activate a license, the app sends your license key and a pseudonymous device identifier (a one-way SHA-256 hash derived from hardware identifiers, which we treat as personal data) to our activation service; we store the key, machine hash, activation time, IP address, and user-agent of that request to enforce the per-license activation limit and prevent fraud; (2) when you check for updates, the app requests version metadata from our service; (3) if you download an optional speech model or GPU pack, it is fetched from our service or from the model's hosting provider (Hugging Face), whose own privacy policy applies to that download.

What the app stores locally on your device: settings, transcripts you choose to keep, license/activation tokens, and signed trial state (in application data files and, on Windows, the Windows registry; on macOS, application support files). Uninstalling removes the application; local data can be removed per the instructions in our documentation.

Activation records are retained for the life of the license plus 3 years, then deleted or anonymized. To exercise privacy rights (access, deletion) over purchase or activation records, contact the address in Section 20, referencing your order email.

When you purchase ALAN Echo through our website, the website (not the application) collects your email address for license delivery and our payment processor, Stripe, processes your payment. We retain a record of issued license keys and purchase emails to provide key recovery, refunds, and abuse prevention. Those website practices are governed by the rest of this Privacy Policy.

§11

ALAN Social Desk (Our Own Social Media Accounts)

ALAN Social Desk is an internal, staff-only tool we use to publish our own video content to social media accounts that ALAN owns and operates, currently our TikTok channel. It is not a feature of the Services, it is not offered to you, and it is not accessible to visitors, subscribers, or enterprise clients. We describe it here because it connects to TikTok's Content Posting API and Login Kit on our behalf.

What it accesses: when a member of our staff authorizes the tool, TikTok issues access and refresh tokens scoped to ALAN's own account. We request two permissions: user.info.basic, which reads that account's own profile information (its open ID, display name, username, and avatar image), and video.publish, which posts video to that account. Using those tokens the tool reads the posting options the account permits, and uploads video files together with the caption, visibility, interaction settings, and any commercial-content or paid-partnership disclosure our staff select.

What it does not do: the tool transmits no information about you, your account, your watchlists, your queries, or any other user data to any social media platform. It does not read, collect, or store information about the people who view, follow, or interact with our posts.

Storage and retention: the tokens are held in one place only, a signed, HTTP-only cookie in the authorizing staff member's browser. We operate no database or other store of them. They expire on TikTok's own schedule; a member of staff can disconnect the account from within the tool at any time, which discards them; and they can be revoked at any time from TikTok's own account settings, which immediately ends the tool's access. Video files are transmitted to TikTok and are not retained by the tool after publication.

Your own interactions with our social media accounts, such as following, viewing, commenting, or messaging, take place on that platform and are governed by the platform's own privacy policy rather than this one. For TikTok, see the TikTok Privacy Policy at https://www.tiktok.com/legal/privacy-policy.

§12

Aggregated and De-Identified Data

ALAN may generate reports, analytics, and performance metrics, and may create and use aggregated, anonymized, or statistical information that does not identify any individual, for purposes including benchmarking, research, security, and improving the Services.

§13

Data Retention

We retain information for as long as reasonably necessary to provide the Services, maintain platform functionality, comply with legal and licensing obligations, resolve disputes, enforce our agreements, and protect system security. Retention periods may vary by the type of information and the context in which it was collected.

§14

Data Security

ALAN implements reasonable administrative, technical, and organizational safeguards designed to protect information against unauthorized access, use, or disclosure. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for safeguarding your account credentials and for activity that occurs under your account.

§15

International Data Transfers

If you access the Services from outside the United States, your information may be transferred to, stored in, and processed in the United States or other countries that may have different data-protection laws than your jurisdiction. Where required, ALAN relies on appropriate transfer mechanisms (such as the EU Standard Contractual Clauses) for cross-border transfers.

§16

Children's Privacy

The Services are intended for users 18 years of age and older and are not directed to children. We do not knowingly collect personal information from children under 13. If we learn that we have collected such information, we will take reasonable steps to delete it and when necessary alert required law enforcement or other agencies.

§17

Your Privacy Rights

Depending on your location, you may have rights under applicable privacy laws, which may include the right to:

Access the personal information we hold about you
Correct inaccurate information
Request deletion of personal information
Obtain a copy of your personal information (portability)
Opt out of certain uses of your information

To exercise these rights, contact us at alanglobalintelligence@proton.me. We may take reasonable steps to verify your identity before responding and will respond within the timeframes required by applicable law.

§18

State Privacy Rights (United States)

Residents of California and other states with comprehensive consumer-privacy laws may have additional rights, which may include the rights to know, access, correct, delete, and obtain a copy of their personal information, and to opt out of the "sale" or "sharing" of personal information and of certain profiling.

We do not sell your personal information, and we do not share it for cross-context behavioral advertising, as those terms are defined under applicable state law. To the extent we process any sensitive personal information, we use and disclose it only as permitted by applicable law and to provide the Services you request. Residents may exercise their rights using the contact information in Section 20, and you will not be discriminated against for exercising your rights. Where permitted, you may use an authorized agent to submit a request.

§19

Changes to This Privacy Policy

We may update this Privacy Policy periodically. As with any section in this policy, we reserve the right to change, alter or otherwise amend this policy according to applicable Federal and State laws and regulations. Updates will be posted on this page with a revised "Last Modified" date and, where required by law, communicated to you.

§20

Contact Information

For privacy-related questions, data deletion requests, or to exercise your rights, contact us at alanglobalintelligence@proton.me / alanglobalintelligence.com

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