Privacy Policy

Last updated: September 2026 · Data controller: The APES Company LLC

1. Introduction

The APES Company LLC respects your privacy and is committed to protecting your personal data. This Privacy Policy outlines how we collect, use, store, and process information when you use our website and SaaS platform.

2. Data We Collect

• Account Registration Data: Basic contact details provided during signup (such as email address).
• Brokerage Integration Data: Credentials or authentication tokens processed via secure third-party APIs (such as SnapTrade) to sync equity portfolios. In accordance with our data minimization policy, raw transaction histories are processed in volatile server RAM and purged from active database storage.
• Technical Telemetry: IP addresses, browser types, device identifiers, and region origin data used for security validation and billing compliance.

3. Privacy-Centric Architecture (No Behavioral Tracking)

Our platform operates on a privacy-conscious model. We do not engage in behavioral user profiling, nor do we deploy third-party advertising cookies or cross-site tracking pixels. Content delivery and interface security walls are maintained without tracking individual browsing histories across external web properties.

4. Legal Basis for Processing (GDPR & EU/Netherlands Compliance)

For users residing in the European Union (including the Netherlands) and the United Kingdom, we process your personal data under the following legal bases:

• Performance of a Contract: Processing necessary to provide you with the software platform and maintain your subscription.
• Legitimate Interests: Processing necessary to ensure platform security, prevent bot scraping, and maintain data integrity of crowdsourced ledgers.
• Legal Compliance: Adhering to tax, accounting, and Merchant of Record obligations.

5. Third-Party Processors & Merchant of Record

Financial checkouts and payment transactions are processed securely through our global Merchant of Record, Paddle. Paddle collects billing details and local transaction taxes natively on its secure infrastructure. We do not store full credit card numbers on our servers.

6. Data Retention and Security

We employ administrative, technical, and physical safeguards—including Cloudflare web application firewalls and encrypted database channels—to secure your information. Data is retained only as long as necessary to fulfill the purposes outlined in this policy or to comply with legal requirements.