Privacy Policy

This Privacy Notice for Stowe Stats LLC (doing business as Vibe Check) (“we,” “us,” or “our”) describes how and why we might access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you:

• Visit our website at https://vibe.stowestats.com or any website of ours that links to this Privacy Notice
• Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at vibe@stowestats.com.

Summary of Key Points

This summary provides key points from our Privacy Notice. You can find more detail in the sections below.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the features you use.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process your information only when we have a valid legal reason to do so.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission or storage technology can be guaranteed to be 100% secure.

What are your rights? Depending on where you are located, applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way is by emailing us at vibe@stowestats.com, or by using the account controls described below. We will consider and act upon any request in accordance with applicable data protection laws.

1. What information do we collect?

Personal information you disclose to us. We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our Services, when you participate in activities on the Services, or otherwise when you contact us. The personal information we collect may include:

• names
• email addresses
• usernames
• passwords
• user-generated journal content (check-ins, plans, reviews, notes, mantras, screenshots, and imported trade data)

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected. We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal reporting purposes. It includes log and usage data (diagnostic, usage, and performance information our servers automatically record in log files) and device data (information about the computer, phone, tablet, or other device you use to access the Services).

2. How do we process your information?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts — so you can create and log in to your account, and keep your account in working order.
• To deliver and facilitate delivery of services to the user — to provide you with the requested service.
• To respond to user inquiries and offer support — to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you — details about our Services, changes to our terms and policies, and other similar information.
• To request feedback — to contact you about your use of our Services.
• To protect our Services — including fraud monitoring and prevention.
• To identify usage trends — to better understand how our Services are used so we can improve them.
• To save or protect an individual’s vital interest — when necessary to prevent harm.
• To create aggregated and de-identified data — we may combine and anonymize personal information from many users so the resulting data set cannot reasonably be linked back to any individual user. This may include trends in readiness, plan adherence, and behavioral patterns derived from journal content and imported trade data. You can opt out of this at any time in Settings → Research & insights.

3. What legal bases do we rely on?

We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law.

If you are located in the EU or UK, the GDPR and UK GDPR require us to explain the valid legal bases we rely on. We may rely on:

• Consent — you can withdraw your consent at any time.
• Performance of a contract — to provide our Services to you.
• Legitimate interests — including to analyze how our Services are used so we can improve them; diagnose problems and prevent fraud; understand how users use our products so we can improve experience; and to improve the Service, study patterns in trader psychology and performance, share aggregate insights publicly, and develop new features. Aggregated and de-identified data is not personal information under applicable privacy laws. You can opt out of having your data included in this aggregate research at any time in Settings → Research & insights.
• Legal obligations — to comply with the law, cooperate with law enforcement, or defend our legal rights.
• Vital interests — to protect your vital interests or those of a third party.

If you are located in Canada, we may process your information where you have given express or implied consent. In certain exceptional cases permitted by law, we may process your information without your consent (for example, for fraud detection and prevention, to investigate a breach of an agreement, or to comply with a subpoena or court order). We may disclose de-identified information for approved research or statistics projects, subject to confidentiality commitments.

4. When and with whom do we share your personal information?

We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us and require access to such information to do that work. We have contracts in place designed to safeguard your personal information; they cannot use it for anything other than what we instruct, and they will not share it with any organization apart from us. The categories of third parties we may share personal information with are:

• Cloud Computing Services
• Data Storage Service Providers
• User Account Registration & Authentication Services
• Website Hosting Service Providers
• Communication & Collaboration Tools

We may also share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. Do we use cookies and other tracking technologies?

We use cookies that are strictly necessary to provide and secure the Services. Specifically, we use a session cookie set by our authentication provider to keep you logged in and to maintain the security of your account. These cookies are essential to the basic functioning of the Services and cannot be switched off in our systems.

We do not use cookies or similar tracking technologies for advertising, marketing, behavioral analytics, or to track you across other websites. We do not permit third parties to place advertising or analytics trackers on our Services. Because we use only strictly necessary cookies, you can manage or block them through your browser settings, but doing so may prevent you from logging in or using core features.

6. Is your information transferred internationally?

Our servers are located in the United States. Regardless of your location, your information may be transferred to, stored by, and processed by us and the third parties with whom we share it, including in the United States and other countries. If you are a resident in the EEA, UK, or Switzerland, these countries may not have data protection laws as comprehensive as those in your country; however, we take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law, including by using the European Commission’s Standard Contractual Clauses for transfers between us and our third-party providers. Our Standard Contractual Clauses can be provided upon request.

7. How long do we keep your information?

We keep your personal information only for as long as necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law. No purpose in this notice will require us keeping your personal information for longer than the period of time in which you have an account with us. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if that is not possible (for example, because it is stored in backup archives), securely store it and isolate it from further processing until deletion is possible.

8. How do we keep your information safe?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. Do we collect information from minors?

Vibe Check is intended for users who are 18 years of age or older. We do not knowingly collect personal information from anyone under 18. If you are under 18, please do not create an account or submit any personal information through the Service. If we become aware that we have collected personal information from a user under 18, we will take prompt steps to delete that information. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at vibe@stowestats.com.

10. What are your privacy rights?

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right to request access and obtain a copy of your personal information, to request rectification or erasure, to restrict the processing of your personal information, to data portability, and not to be subject to automated decision-making. In certain circumstances you may also have the right to object to the processing of your personal information. To make a request, contact us using the details in the “How can you contact us” section below.

If you are located in the EEA or UK and believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent. If we are relying on your consent, you have the right to withdraw it at any time by contacting us or updating your preferences. This will not affect the lawfulness of processing before its withdrawal.

Opting out of marketing. If you ever receive marketing communications from us, you can unsubscribe at any time using the link in those emails or by contacting us. We may still send service-related messages necessary for the administration of your account.

Account information. You can review or change your account information at any time by logging in to your account settings. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases, though we may retain some information to prevent fraud, troubleshoot problems, assist with investigations, enforce our legal terms, and/or comply with applicable legal requirements.

11. Controls for do-not-track features

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature you can activate. No uniform technology standard for recognizing and implementing DNT signals has been finalized, so we do not currently respond to DNT browser signals. California law requires us to disclose how we respond to such signals; because there is no industry or legal standard for recognizing or honoring them, we do not respond to them at this time.

12. Do United States residents have specific privacy rights?

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent. These rights may be limited in some circumstances by applicable law.

Categories of personal information we have collected in the past twelve (12) months:

We retain Category A and Category B information for as long as you have an account with us. We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed Category A (Identifiers) and Category B (California Customer Records) information to our service providers for business purposes.

Your rights. These include the right to know whether we are processing your personal data, to access it, to correct inaccuracies, to request deletion, to obtain a copy, to non-discrimination for exercising your rights, and to opt out of processing for targeted advertising, the sale of personal data, or certain profiling. Depending on your state, you may have additional rights regarding categories of data processed and third parties to whom data has been disclosed.

How to exercise your rights. Email us at vibe@stowestats.com, or submit access and deletion requests directly through your account by visiting Settings → Danger Zone within the application. You may designate an authorized agent to make a request on your behalf, subject to verification. Upon receiving your request, we will verify your identity using the information we maintain about you.

Appeals. If we decline to take action regarding your request, you may appeal by emailing us at vibe@stowestats.com. We will inform you in writing of any action taken or not taken and the reasons. If your appeal is denied, you may submit a complaint to your state attorney general.

13. Do we make updates to this notice?

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated “Last updated” date at the top. If we make material changes, we may notify you by prominently posting a notice or by directly sending you a notification. We encourage you to review this Privacy Notice frequently.

14. How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at vibe@stowestats.com or contact us by post at:

Stowe Stats LLC
[Mailing address to be added]
United States

15. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country or US state of residence, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent. To make such a request, email us at vibe@stowestats.com.

Questions, requests, or concerns? Email vibe@stowestats.com.