Privacy Policy

Effective Date: April 18, 2026·Last Updated: April 18, 2026

PUDZEE COPILOT PRIVACY POLICY

This Privacy Policy ("Policy") describes how Pudzee LLC ("Pudzee," "we," "us," or "our") collects, uses, discloses, stores, and safeguards information in connection with your access to and use of the Pudzee Copilot platform and related websites, dashboards, checkout flows, browser-based panels, communications, and services (collectively, the "Service").

This Policy is incorporated by reference into the Terms of Service and forms part of the binding agreement between you and Pudzee.

1. Scope

This Policy applies to personal information and related data collected through:

  • The Pudzee website and account system
  • The Copilot web application, dashboards, and browser-based panels
  • Trade alerts, execution-map, trade-desk-insights, performance-dashboard, and related Service features
  • Checkout, billing, purchase-confirmation, and entitlement flows
  • Support, account, security, admin, and affiliate-program workflows
  • Email and other communications relating to the Service

This Policy does not apply to third-party brokers, exchanges, proprietary trading firms, payment processors, websites, or platforms that you access independently of Pudzee and that operate under their own privacy policies.


2. Information We Collect

2.1 Information You Provide Directly

We may collect information you provide to us directly, including:

  • Account information such as email address and password
  • Profile information such as country or other account settings you choose to provide
  • Records of acceptance of the Terms of Service and Privacy Policy, including acceptance timestamps
  • Support requests, communications, and feedback
  • Billing or purchase-related information you submit through our checkout or account flows
  • Password-reset requests and related account-recovery information
  • Content or files you choose to submit through Service features, support channels, or admin workflows
  • Affiliate-program information if you apply for or participate in the affiliate program, such as display name, channel information, channel URL, payout email, and related application or payout details

When you create an account, we store your password in hashed form rather than plaintext.

2.2 Information We Collect Automatically

When you access or use the Service, we may automatically collect technical, usage, and event information, including:

  • Device, browser, operating system, and general technical environment information
  • IP address, user agent, approximate location, and country information
  • Session identifiers, authentication events, timestamps, and log records
  • Feature usage, page interactions, selected instruments, session-window activations, entitlement checks, and diagnostic information
  • Error logs, crash data, reliability data, and performance telemetry
  • Device or browser identifiers used to maintain sessions, detect abuse, or support fraud prevention

Certain technical identifiers, including IP addresses, persistent identifiers, session cookies, and device fingerprints, may be considered personal data under applicable law.

2.3 Purchases, Passes, and Entitlement Records

If you purchase access to the Service, we may collect or generate records relating to your transaction and entitlement status, including:

  • Product or pass selections
  • Instrument selections and access windows
  • Transaction status, timestamps, payment identifiers, and provider references
  • Pending-purchase records and fulfillment status
  • Pass purchase records, expiration times, utilization records, and related account entitlements
  • Risk-acknowledgment or refund-acknowledgment timestamps where presented in checkout or purchase flows
  • Feature-interaction records tied to account access or entitlements, such as engagement, resolution, deletion, or credits/usage events within certain Service tools

2.4 Payment Information and Payment Fingerprints

Payments are processed by third-party payment processors. Pudzee does not store full payment card numbers.

We may receive limited payment-related metadata from processors or related internal services, including:

  • Payment status
  • Transaction timestamps
  • Product or price identifiers
  • Provider event identifiers
  • Limited fraud-prevention or verification metadata

We may also record payment-method fingerprint information supplied by a processor or related internal service for fraud prevention, duplicate-account detection, dispute handling, affiliate attribution controls, or abuse monitoring.

2.5 Device Fingerprints and Security Data

We may generate or store device- or browser-linked identifiers to support account integrity, entitlement enforcement, and fraud prevention. Depending on the feature or flow, this may include:

  • Locally stored install identifiers or device identifiers
  • Browser or device fingerprints
  • IP address and user-agent information associated with a device record
  • Country information associated with a device or session
  • Records of how many times a device has been seen for a given account

2.6 Cookies, Local Storage, and Session Storage

We may use cookies and similar client-side storage technologies, including browser local storage and session storage, to operate the Service. Examples may include:

  • Authentication and session cookies
  • Referral or affiliate cookies
  • Local storage used to maintain a stable install ID or device fingerprint
  • Session storage used to preserve checkout, pending-purchase, or redirect state during payment flows
  • Local settings used for convenience or feature continuity

2.7 Affiliate and Referral Data

If you interact with affiliate or referral features, we may collect and use:

  • Referral codes or promotion codes
  • Referral cookie values
  • Click-attribution data such as timestamp, landing URL, IP hash, or user agent
  • Affiliate application data and approval status
  • Commission, ledger, payout, and audit records

2.8 Performance Profiles and Trading Account Data

If you use performance-dashboard or performance-profile features, we may store and process records such as:

  • Performance profile identifiers, display settings, and profile visibility status
  • Linked trading-account metadata, such as broker platform, broker account ID, account label, account type, currency, and sync timestamps
  • Imported or synchronized account data, including orders, trades, fills, executions, account snapshots, and risk snapshots
  • Derived performance metrics, history, and rollups based on synchronized trading-account data

If a performance profile is configured as public, certain profile information or aggregated performance information may be viewable to others.

2.9 Information We Do Not Collect

Pudzee does not, through the Service:

  • Access or store your broker or exchange login credentials
  • Access or control your brokerage or exchange account on your behalf
  • Execute, route, or place trades for you
  • Collect biometric identifiers
  • Intentionally collect government-issued identification numbers unless specifically required for a separate process not covered by the standard Service flow

3. How We Use Information

We may use information we collect to:

  • Create and manage accounts
  • Authenticate users and maintain sessions
  • Deliver the Service and its features, including trade alerts, execution-map views, trade-desk-insights content, performance-dashboard access, Market State, Market Internals, Options Flow, and related entitlements
  • Process purchases, confirm payments, activate passes, maintain access windows, and administer related billing records
  • Prevent fraud, detect abuse, investigate duplicate or suspicious activity, enforce account integrity, review or restrict suspicious accounts or transactions, and protect the Service
  • Operate internal admin, audit, and support functions
  • Send transactional communications such as welcome emails, password reset emails, and support responses
  • Improve system performance, reliability, security, and user experience
  • Operate performance-dashboard, profile, sync, and analytics features where available
  • Administer affiliate, referral, and payout workflows if applicable
  • Comply with legal obligations, enforce agreements, respond to disputes, and protect rights, property, safety, or security

We do not use personal information to provide individualized investment, trading, or financial advice.

We do not engage in automated decision-making or profiling that produces legal or similarly significant effects solely through automated means.

Market data, trade alerts, execution-map outputs, trade-desk-insights content, performance metrics, Market State, Market Internals, Options Flow, and similar Service outputs are not treated as personal information merely because they are displayed to a user, unless they are combined with personal account records in a manner that identifies a specific user.


4. Analytics, Diagnostics, and Aggregation

We may analyze usage, security, and operational data in aggregated, de-identified, or otherwise non-user-identifying form to:

  • Understand usage patterns
  • Measure performance and reliability
  • Improve product design and feature quality
  • Support internal analytics, testing, and research and development

We may use third-party analytics tools, including Google Analytics, to measure website traffic, checkout activity, page visits, and engagement with the Copilot web application and browser-based panel.

Where data has been aggregated or de-identified so that it no longer reasonably identifies a user, we may use that information for operational and analytical purposes.


5. How We Share Information

We may share information only in the limited circumstances described below.

5.1 Service Providers and Infrastructure

We may share information with vendors or contractors that perform services for us, such as:

  • Payment processing and payment operations
  • Hosting, cloud infrastructure, databases, and storage
  • Authentication and session services
  • Email delivery and support communications
  • Monitoring, logging, analytics, and error tracking
  • Security, fraud prevention, and abuse detection

These providers may access information only as reasonably necessary to perform services for Pudzee, subject to contractual, confidentiality, or other appropriate restrictions.

5.2 Internal Operational Sharing

We may share information across Pudzee-controlled systems and service components as reasonably necessary to operate the Service, including to:

  • Authenticate users
  • Verify entitlements and session access
  • Process purchases and payment confirmations
  • Record device or payment fingerprints for fraud prevention
  • Support admin, audit, and support workflows

5.3 Affiliates, Referrals, and Payout Operations

If you participate in affiliate or referral workflows, relevant data may be shared with service providers or internal systems involved in attribution, commission tracking, fraud screening, and payout administration.

5.4 Legal, Compliance, and Protection

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

  • Comply with applicable law, regulation, subpoena, court order, or governmental request
  • Enforce our agreements or policies
  • Investigate fraud, abuse, security incidents, chargebacks, or disputes
  • Protect the rights, property, safety, or security of Pudzee, users, or others

5.5 Business Transfers

We may transfer information in connection with a merger, acquisition, financing, restructuring, sale of assets, bankruptcy, or similar corporate transaction, subject to appropriate confidentiality or legal constraints.

5.6 No Sale of Personal Information for Money

We do not sell your personal information for money. We do not rent your personal information to data brokers.


6. Cookies and Client-Side Storage

We may use cookies, browser storage, and similar technologies to:

  • Keep you signed in
  • Maintain session continuity and authentication state
  • Remember settings or feature preferences
  • Preserve checkout and purchase-flow state
  • Support referral attribution
  • Measure traffic and product engagement through analytics technologies, including Google Analytics where enabled
  • Generate or store install identifiers or device fingerprints
  • Help detect abuse and protect account integrity

You may be able to control cookies and client-side storage through your browser or device settings. If you block or clear cookies, local storage, or session storage, some parts of the Service may stop working properly.


7. Data Retention

We retain personal information for as long as reasonably necessary to:

  • Provide and maintain the Service
  • Manage accounts, purchases, access rights, and support
  • Detect and investigate fraud, abuse, chargebacks, or disputes
  • Maintain operational, security, accounting, tax, legal, and audit records
  • Enforce agreements and protect the Service

Different categories of information may be retained for different periods depending on operational needs, legal obligations, dispute risk, and system design. Some records, such as pending purchase records, password reset records, session-related information, fraud-monitoring data, or audit logs, may be retained for shorter or longer periods depending on their purpose.


8. Data Security

We implement reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, disclosure, alteration, or misuse.

However, no security measure is perfect, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your credentials and for using the Service on systems you reasonably trust.


9. User Rights and Choices

Depending on your jurisdiction and subject to applicable exceptions, you may have the right to request that we:

  • Confirm whether we process certain personal information about you
  • Provide access to certain personal information
  • Correct inaccurate personal information
  • Delete certain personal information
  • Restrict or object to certain processing where applicable

You may also be able to update limited account information directly through the Service, such as country or password settings where those features are available.

We may need to verify your identity before acting on a request. We may deny or limit requests where permitted by law, including where retention is necessary for fraud prevention, security, transaction completion, legal compliance, recordkeeping, dispute resolution, or enforcement of our agreements.

To submit a privacy-related request, contact us using the contact information below.


10. Children's Privacy

The Service is not intended for individuals under 18 years of age. Pudzee does not knowingly collect personal information from children under 18 through the standard Service.


11. International Users

If you access the Service from outside the United States, you understand that your information may be processed and stored in the United States or other jurisdictions that may have different data-protection laws than your home jurisdiction.


12. Changes to This Policy

We may update this Policy from time to time. If we make material changes, we may provide notice by posting the updated Policy within the Service, by email, or by other reasonable means.

Unless otherwise stated, the updated Policy will be effective when posted or on the effective date shown at the top of the updated document.


13. Contact

Pudzee LLC
Pennsylvania, USA
Email: legal@pudzee.com