Privacy Policy

1. Introduction

Snowtrail Research Ltd ("Snowtrail", "we", "our", or "us") is committed to protecting the privacy and security of your information. This Privacy Policy explains how we collect, use, disclose, retain, and safeguard information when you visit our website, use our API, SDK, or any other services we provide (collectively, the "Services"). This policy applies to all clients, prospective clients, and website visitors.

2. Information We Collect

We collect the following categories of information:

Account Information

• Name, email address, company name, and job title provided when you request a demo, create an account, or contact us
• Billing contact details and payment information (processed by our third-party payment provider -- see Section 7)
• API keys and access credentials associated with your account

API Usage and Service Logs

• API request metadata: endpoints accessed, request timestamps, response codes, and request volume
• IP addresses used to access the Services
• SDK version and client configuration details

Website Analytics

• Browser type, device information, operating system, and referring URLs
• Pages visited, time spent on pages, and navigation patterns
• Cookies and similar tracking technologies (see Section 9)

3. Information We Do NOT Collect

Snowtrail Research is a B2B data analytics provider. We want to be clear about what we do not collect:

• We do not collect, store, or have access to your trading positions, portfolio holdings, or order flow
• We do not collect personal financial or investment account information
• We do not track how you use our data in your internal trading or risk systems
• We do not collect data from end users of your systems or applications

4. How We Use Your Information

We use the information we collect for the following purposes:

• Service delivery -- to authenticate your access, deliver data products, and maintain your account
• Service improvement -- to monitor platform performance, identify errors, and improve reliability
• Usage management -- to enforce rate limits, detect abuse, and ensure fair use of shared resources
• Customer support -- to respond to your enquiries and resolve technical issues
• Billing -- to process payments and manage your subscription
• Communications -- to send service-related notices, product updates, and scheduled maintenance alerts
• Legal compliance -- to comply with applicable laws, regulations, and legal processes

5. Lawful Basis for Processing (GDPR)

For individuals in the European Economic Area (EEA) and United Kingdom, we process personal data under the following lawful bases:

• Performance of a contract -- processing necessary to deliver the Services you have subscribed to
• Legitimate interests -- processing necessary for our legitimate business interests, such as improving the Services, ensuring platform security, and communicating product updates, provided these interests are not overridden by your rights
• Legal obligation -- processing required to comply with applicable laws and regulations
• Consent -- where you have provided explicit consent, such as opting into marketing communications. You may withdraw consent at any time

6. Data Retention

We retain information for as long as necessary to fulfil the purposes described in this policy:

• API usage logs -- retained for ninety (90) days, then automatically deleted
• Account information -- retained for the duration of your subscription and for a reasonable period thereafter to fulfil legal and accounting obligations
• Billing records -- retained for the period required by applicable tax and accounting regulations (typically 6-7 years)
• Website analytics -- retained for up to twelve (12) months
• Support correspondence -- retained for up to twenty-four (24) months after resolution

7. Third-Party Services

We use the following categories of third-party service providers in the operation of our Services:

• Cloud infrastructure -- Amazon Web Services (AWS) provides the hosting, compute, storage, and networking infrastructure for the Services. Data is processed and stored in AWS data centres
• Payment processing -- Stripe processes subscription payments on our behalf. Snowtrail does not store full credit card numbers or payment card details. See Stripe's Privacy Policy for details
• Email communications -- we use third-party email services to send transactional and service-related communications
• Analytics -- we may use website analytics tools to understand how visitors interact with our website

We require all third-party providers to process data in accordance with applicable data protection laws and to maintain appropriate security measures.

8. Data Security

We implement appropriate technical and organisational measures to protect your information, including:

• Encryption in transit -- all data transmitted between your systems and our Services is encrypted using TLS (Transport Layer Security)
• Encryption at rest -- data stored in our systems is encrypted at rest using AWS S3 Server-Side Encryption (SSE) and equivalent mechanisms for other storage services
• Access controls -- access to personal data is restricted to authorised personnel on a need-to-know basis
• API authentication -- all API access requires valid credentials and is subject to rate limiting and monitoring
• Infrastructure security -- our cloud infrastructure is managed using infrastructure-as-code practices with security controls applied at the network, compute, and storage layers

While we take commercially reasonable precautions, no method of electronic storage or transmission is 100% secure. We cannot guarantee absolute security but are committed to promptly addressing any security incidents in accordance with applicable law.

9. Cookies

Our website may use cookies and similar technologies to improve your browsing experience and to analyse website traffic. You can control cookie preferences through your browser settings. Essential cookies required for the website to function cannot be disabled. We do not use cookies to track your use of our API or data products.

10. Your Rights (GDPR and UK Data Protection)

If you are located in the EEA or United Kingdom, you have the following rights under applicable data protection law:

• Right of access -- to request a copy of the personal data we hold about you
• Right to rectification -- to request correction of inaccurate or incomplete personal data
• Right to erasure -- to request deletion of your personal data, subject to legal retention obligations
• Right to restrict processing -- to request that we limit the processing of your personal data in certain circumstances
• Right to data portability -- to request a copy of your data in a structured, machine-readable format
• Right to object -- to object to processing based on legitimate interests or for direct marketing purposes
• Right to withdraw consent -- where processing is based on consent, you may withdraw it at any time

To exercise any of these rights, please contact us at privacy@snowtrail.ai. We will respond to all legitimate requests within thirty (30) days. You also have the right to lodge a complaint with a supervisory authority if you believe your data protection rights have been violated.

11. International Data Transfers

Your information may be transferred to and processed in countries other than the country in which you reside. Where we transfer personal data outside the EEA or UK, we ensure that appropriate safeguards are in place in accordance with applicable data protection law, including standard contractual clauses or other approved transfer mechanisms.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will notify you of material changes by posting an updated version on our website and, where appropriate, by email. The "Last updated" date at the top of this page indicates when the policy was most recently revised.

13. Contact Us

If you have questions about this Privacy Policy or wish to exercise your data protection rights, please contact us at:

Snowtrail Research
Privacy enquiries: privacy@snowtrail.ai
General enquiries: info@snowtrail.ai