AXIOM Privacy Policy

1. Introduction

This Privacy Policy explains how MNA Research, LLC collects, uses, discloses, and safeguards personal information in connection with AXIOM and related websites, dashboards, account functions, subscriptions, communications, and services (collectively, the "Service").

AXIOM is a product operated by MNA Research, LLC.

This Policy applies only to personal information processed by MNA Research in connection with the Service. It does not govern independent websites or services operated by third parties.

2. Information We Collect

2.1 Account and Authentication Information

When you create or use an AXIOM account, we may process information such as:

• name;
• email address;
• account identifiers;
• authentication status;
• account creation and login timestamps; and
• related account-security information.

AXIOM uses Firebase Authentication as its authentication provider.

MNA Research does not store your password in its own AXIOM application database. Authentication credentials are handled by the authentication provider according to its systems and policies.

2.2 Subscription and Payment Information

Payments may be processed by Stripe or another payment processor used by MNA Research.

Depending on the checkout configuration, MNA Research may receive or maintain information such as:

• customer name;
• billing email;
• billing address;
• subscription status;
• plan or package;
• transaction identifiers;
• payment status;
• renewal status;
• cancellation status;
• invoice information; and
• limited payment-method metadata supplied by the processor.

MNA Research does not store your full payment-card number in its AXIOM application systems.

2.3 Communications and Support

If you contact MNA Research, we may collect:

• your name and email address;
• the content of your message;
• screenshots or files you choose to provide;
• technical information relevant to a support issue; and
• records of our response.

2.4 Service Preferences

We may process preferences and configuration information that you choose to save within AXIOM, including:

• alert preferences;
• display preferences;
• watchlist or symbol preferences;
• layout or dashboard settings; and
• other user-selected configuration settings.

2.5 Usage, Device, and Technical Information

When you use AXIOM, we may automatically collect or generate information such as:

• IP address;
• browser type and version;
• device and operating-system information;
• session timestamps;
• pages, dashboards, or features accessed;
• error logs;
• authentication events;
• security events;
• API or network request metadata where applicable;
• referring pages;
• approximate location derived from IP address where used for security or compliance; and
• other diagnostic or usage information reasonably necessary to operate and secure the Service.

2.6 Cookies and Similar Technologies

AXIOM may use cookies, local storage, authentication tokens, or similar technologies necessary to:

• keep users signed in;
• maintain account sessions;
• remember settings;
• prevent fraud or abuse;
• protect account security; and
• operate core Service functionality.

AXIOM uses Google Analytics and other analytics tools to better understand how visitors and subscribers use the Service, so we can improve the product. Some of these tools, including Google Analytics, use cookies and process information such as your IP address and device/browser identifiers; where required by applicable law (such as the GDPR and ePrivacy Directive in the EU/UK), these do not run until you affirmatively accept them through the consent banner presented on the Service, and you may decline or change that choice at any time. Other analytics tools we use operate on an aggregate, anonymized basis that does not require consent under applicable frameworks.

If AXIOM later uses additional non-essential analytics, advertising, or tracking technologies that require further disclosure or consent, this Policy and any applicable consent controls will be updated accordingly.

3. Information We Do Not Intentionally Collect Through AXIOM

AXIOM is an analytics and modeling product and does not connect to your brokerage account as part of its standard Service.

Unless a future feature is expressly introduced and separately disclosed, MNA Research does not intentionally collect through AXIOM:

• brokerage login credentials;
• your complete brokerage account information;
• your live brokerage positions;
• your order-entry credentials;
• your bank-account login credentials; or
• your full payment-card number.

If the product changes materially, this Policy will be updated before or when required by applicable law.

4. How We Use Personal Information

MNA Research may use personal information to:

• create and administer accounts;
• authenticate users;
• provide access to purchased subscription packages;
• process billing, renewals, cancellations, and payment-related support;
• provide, operate, maintain, and improve AXIOM;
• remember user settings and preferences;
• provide technical and customer support;
• investigate bugs, data issues, service outages, and account problems;
• secure the Service and detect fraud, abuse, scraping, account sharing, or unauthorized access;
• maintain logs and audit records;
• analyze aggregate or de-identified Service usage;
• communicate operational, billing, legal, account, or security notices;
• enforce our Terms of Service;
• comply with legal, tax, accounting, regulatory, or court requirements; and
• establish, exercise, or defend legal rights.

MNA Research does not use AXIOM account information to train a third-party general-purpose artificial-intelligence model.

5. How We Share Personal Information

MNA Research does not sell personal information for money.

We may share personal information with the following categories of recipients where reasonably necessary:

5.1 Service Providers

We may disclose information to vendors that perform services for MNA Research, such as:

• authentication providers, including Firebase Authentication;
• payment processors, including Stripe where used;
• cloud, hosting, database, logging, monitoring, security, and infrastructure providers;
• customer-support or communications providers; and
• professional advisers such as attorneys, accountants, or auditors.

These providers receive information only as reasonably necessary for the services they perform for us and are subject to their own contractual and legal obligations.

5.2 Legal, Compliance, and Safety Disclosures

We may disclose information where we reasonably believe disclosure is necessary to:

• comply with applicable law, subpoena, court order, or lawful governmental request;
• investigate fraud or misuse;
• protect the security or integrity of AXIOM;
• enforce agreements;
• protect MNA Research, its users, or others; or
• establish, exercise, or defend legal claims.

5.3 Business Transactions

If MNA Research is involved in a merger, acquisition, financing, restructuring, sale of assets, or similar corporate transaction, personal information may be disclosed or transferred as part of that transaction subject to applicable law.

5.4 Market-Data Providers

MNA Research's commercial market-data provider does not presently require AXIOM to provide subscriber entitlement information or subscriber personal information as part of the arrangement described to us.

If that arrangement materially changes and personal information must be shared with a market-data provider, MNA Research will update this Policy as required.

6. No Sale of Personal Information

MNA Research does not sell personal information for monetary consideration.

If MNA Research later engages in activity legally defined as a "sale," "sharing," or targeted advertising under an applicable privacy law, we will provide the disclosures and choices required by that law.

7. Data Security

MNA Research uses administrative, technical, and organizational safeguards designed to protect personal information.

These measures may include:

• encrypted network connections;
• authentication controls;
• role-based or limited access;
• account-security monitoring;
• logging;
• vendor security controls; and
• other measures appropriate to the nature of the Service.

No internet-connected system is completely secure. MNA Research cannot guarantee absolute security or that a security incident will never occur.

If a security incident triggers a legal notification obligation, MNA Research will provide notices as required by applicable law.

8. Data Retention

MNA Research retains personal information only for as long as reasonably necessary for the purposes described in this Policy, including:

• providing and securing the Service;
• maintaining account and transaction records;
• resolving disputes;
• enforcing agreements;
• satisfying tax, accounting, legal, regulatory, or compliance obligations; and
• establishing or defending legal claims.

Different categories of information may be retained for different periods.

Where permitted and practicable, information may be deleted, anonymized, or aggregated when it is no longer reasonably necessary.

We do not promise a fixed retention period for every category of information unless expressly stated elsewhere.

9. Your Privacy Choices and Rights

Depending on where you reside and which privacy laws apply to MNA Research, you may have rights concerning your personal information.

These may include a right to:

• request access to personal information;
• request correction;
• request deletion;
• request a copy or portability of certain information;
• object to or restrict certain processing;
• withdraw consent where processing is based on consent;
• opt out of certain legally defined sales, sharing, targeted advertising, or profiling; and
• appeal certain privacy-request decisions where required by law.

These rights are not identical in every jurisdiction, and some rights may not apply to MNA Research or to a particular request.

To submit a privacy request, contact [email protected].

MNA Research may need to verify your identity before fulfilling a request and may retain information where permitted or required by law.

10. California Privacy Notice

To the extent the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA"), applies to MNA Research or a particular processing activity, California residents may have rights provided by that law.

Such rights may include rights to know, access, correct, delete, and obtain information concerning certain disclosures, as well as rights to opt out of certain legally defined "sale" or "sharing" activities.

MNA Research does not sell personal information for money.

Nothing in this Section is intended to represent that every CCPA/CPRA requirement applies to MNA Research where the statutory applicability requirements are not met.

Requests may be submitted to [email protected].

11. EEA, United Kingdom, and Other International Users

If applicable privacy law, including the European Union General Data Protection Regulation ("GDPR") or United Kingdom GDPR, applies to MNA Research's processing of your personal information, MNA Research will process that information in accordance with the applicable legal requirements.

Depending on the processing activity, an applicable legal basis may include:

• performance of a contract;
• compliance with legal obligations;
• legitimate interests;
• consent; or
• another lawful basis recognized by applicable law.

If applicable law requires a lawful mechanism for transferring personal information across borders, MNA Research will use an appropriate mechanism.

Mere use of AXIOM is not intended to substitute for any legally required international-data-transfer mechanism.

Users may have additional rights under applicable local law, including a right to complain to an appropriate data-protection authority.

12. International Data Processing

MNA Research and its service providers may process information in countries other than the country in which you reside.

Those countries may have different data-protection laws.

Where applicable law requires safeguards for cross-border transfers, MNA Research will use appropriate safeguards or transfer mechanisms.

13. Children's Privacy

AXIOM is not intended for individuals under 18 years of age.

MNA Research does not knowingly seek to collect personal information from individuals under 18 through the Service.

If we learn that we have collected personal information from a person under 18 in circumstances where deletion is appropriate or required, we will take reasonable steps to delete it.

14. Third-Party Websites and Services

AXIOM may contain links to third-party websites or may rely on third-party services.

MNA Research is not responsible for the privacy practices of independent third parties. Their processing is governed by their own terms and privacy policies.

You should review the applicable privacy disclosures of third-party services you choose to use.

15. Changes to This Privacy Policy

MNA Research may update this Privacy Policy from time to time.

The "Last Updated" date will be revised when changes are published.

Where required by law, MNA Research will provide additional notice of material changes.

16. Contact

Questions or privacy requests may be directed to:

MNA Research, LLC

AXIOM Privacy

Email: [email protected]