Privacy Policy

Data handling, disclosed.

How SCT collects, uses, retains, and protects client data. Lawful basis, retention windows, the rights available to clients, and the additional protections we apply for UK and EU users.

01 · Introduction

SCT Consulting LLC, which offers SCT Unlimited as a branded educational software and information product ("SCT," "we," "us," or "our") respects your privacy and is committed to protecting personal information provided to us through our website, the SCT Suite app, dashboards, member portals, onboarding process, support systems, and related services (collectively, the "Services").

This Privacy Policy explains what information we collect, how we use it, how we share it, how long we keep it, what rights you may have regarding your personal information, and the additional protections we apply for users in the United Kingdom, the European Union, and other jurisdictions with equivalent data protection laws.

By using the Services, you acknowledge that you have read and understood this Privacy Policy. Where required by applicable law, we will obtain your explicit consent for specific processing activities before they occur.

02 · Scope of This Policy

This Privacy Policy applies to information collected through:

• The SCT website and any subdomain.
• The SCT Suite app.
• The SCT dashboard and member portal.
• Onboarding forms, Package Selection Forms, and signed agreements.
• Support tickets, email communications, and in-app messages.
• Technical support interactions.
• Payment and billing workflows.
• Compliance, disclosure, and audit records.

This Privacy Policy does not apply to third-party websites, brokers, third-party capital platforms, the supported charting platform, the supported execution platform, payment processors, crypto wallets, banks, or other third-party platforms, each of which has its own privacy policy and terms.

03 · Information We May Collect

SCT may collect personal information you provide directly to us, information generated through your use of the Services, and information from authorised third parties. The categories below describe what we may collect:

A. Identity and Contact Information

• Full name.
• Email address.
• Phone number.
• Billing address.
• Business name, if applicable.
• Authorised signer information, if applicable.
• Discord username or other communication handle, if provided.

B. Account and Onboarding Information

• Package or tier selected.
• Package Selection Form information.
• Signed agreements, risk disclosures, and methodology disclosure receipts.
• Onboarding checklist status and setup status.
• App or dashboard account information.
• Support preferences and technical configuration information needed for support.

C. Platform and Technical Support Information

To provide onboarding, setup assistance, and support, SCT may access or collect certain non-confidential technical information, including:

• Charting-platform username or related charting information, if provided.
• General platform setup information and alert setup status.
• Webhook setup status (without storing sensitive webhook information as a default).
• Screenshots or screen-recordings voluntarily provided for support.
• Device, browser, operating system, and app usage information.
• Error reports, support ticket details, and technical logs.

SCT does not require trading-account login credentials or execution-platform login credentials as a standard part of onboarding. If you voluntarily share sensitive access information for technical support, SCT will use it only for the support purpose requested and will handle it with care under Section 13.

D. Payment and Transaction Information

• Package price and selected payment method.
• Payment status and invoice records.
• Transaction reference numbers and payment plan details.
• Refund, credit, or dispute records.
• Wire, card, cash, crypto, or other payment-related records.

Payment processing may be handled by third-party payment processors, banks, crypto networks, wallet providers, or other service providers. SCT does not control the privacy practices of those third parties.

E. Communications and Support Information

• Emails, support tickets, in-app messages, and dashboard messages.
• Call notes, setup notes, and onboarding notes.
• Support history and dispute or billing communications.

F. App, Dashboard, and Website Usage Information

• Login activity.
• Pages or resources accessed.
• Device type, browser type, and IP address.
• Approximate location derived from IP address.
• Time and date of access.
• App or dashboard activity logs.

04 · Information We Do Not Intend to Collect as Standard

As a software and infrastructure provider, SCT does not require:

• Government-issued identification numbers, except where strictly required by applicable law (for example, tax reporting obligations).
• Bank account numbers, full credit card numbers, or other full financial account credentials. Payment information is collected by third-party payment processors.
• Trading-account passwords, broker login credentials, or third-party capital platform passwords, as a standard part of onboarding.
• Credit reports, credit scores, or other consumer credit information. SCT does not conduct credit checks on prospects or clients as part of its standard licensing process.
• Health, biometric, racial, ethnic, religious, political, sexual orientation, or other special-category information.

If, in a specific workflow, SCT identifies a legitimate business need to collect any category of information outside of its standard collection, SCT will provide a separate, purpose-specific disclosure at the point of collection and, where required by applicable law, obtain your explicit consent before collecting it.

05 · How We Use Information

SCT may use personal information for the following purposes:

• Providing, operating, and improving the Services.
• Onboarding, setup, and configuration support.
• Processing payments, refunds, and invoices.
• Customer support, technical support, and dispute resolution.
• Operational communications, including service notices, security alerts, and policy updates.
• Security, fraud prevention, and abuse detection.
• Compliance with legal, regulatory, tax, accounting, and audit obligations.
• Internal research, analytics, and product development.
• Protection of SCT's rights, intellectual property, methodology documentation, algorithms, and proprietary systems.
• Marketing, retargeting, and advertising communications, but only in accordance with Section 15 and subject to applicable consent requirements.

SCT does not use personal information for purposes other than those listed above unless we obtain your explicit consent or are otherwise required or permitted to do so by applicable law.

06 · Legal Bases for Processing

Where applicable data protection law requires SCT to identify a legal basis for processing personal information (for example, under the UK General Data Protection Regulation, the EU General Data Protection Regulation, or equivalent laws), SCT relies on one or more of the following legal bases:

• Contract: processing necessary to perform a contract with you, or to take steps at your request before entering into a contract (for example, onboarding, providing access to the Services, processing payments, and providing support).
• Legal obligation: processing necessary to comply with a legal, regulatory, tax, accounting, or audit obligation to which SCT is subject.
• Legitimate interests: processing necessary for the legitimate interests of SCT or a third party (for example, security, fraud prevention, protection of intellectual property, and internal analytics), provided those interests are not overridden by your interests, rights, and freedoms.
• Consent: where you have given specific, informed, and freely given consent for a particular processing activity (for example, marketing or targeted advertising under Section 15).
• Vital interests, public interest, or other lawful bases: where applicable law permits processing on such bases.

Where SCT relies on consent, you may withdraw that consent at any time as described in Section 14. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

07 · How We Share Information

SCT does not sell your personal information for money.

SCT may share personal information only as reasonably necessary for legitimate business, operational, legal, or service-related purposes, including with:

• App, dashboard, and website hosting providers.
• Email and communication providers.
• Support and ticketing systems.
• Payment processors, banks, and transaction service providers.
• Contractors, employees, or support team members who need access to provide services.
• Legal, accounting, compliance, tax, audit, and professional advisors.
• Technology service providers used to operate SCT's systems.
• Marketing, analytics, and advertising partners, but only in accordance with Section 15 and subject to applicable consent requirements.
• Law enforcement, regulators, courts, or government authorities when required by law, court order, or lawful process.
• A buyer, successor, investor, or acquiring entity in connection with a merger, acquisition, financing, restructuring, sale of assets, or sale of the company.

SCT may also share information when necessary to protect SCT's rights, protect users, investigate fraud or abuse, enforce agreements, prevent unauthorised use of SCT materials, or respond to legal claims.

08 · Sale of Company or Business Transfer

If SCT is involved in a merger, acquisition, financing, restructuring, sale of assets, sale of the company, or similar business transaction, personal information may be transferred or disclosed as part of that transaction. Any successor or acquiring entity may continue to use personal information consistent with this Privacy Policy, unless otherwise disclosed at the time of the transaction.

09 · Cookies, Analytics, and Tracking Technologies

SCT's website, app, and dashboard may use cookies, pixels, log files, and similar technologies to:

• Keep users logged in.
• Improve website and app performance.
• Understand user activity and onboarding completion.
• Improve the user experience.
• Monitor security and prevent abuse.
• Measure marketing and website performance.

For UK and EU users, and other users in jurisdictions where consent is required, SCT will present a cookie consent interface and will not set non-essential cookies (including analytics, marketing, or retargeting cookies) without your explicit opt-in. Essential cookies necessary for the Services to function may be set without consent in accordance with applicable law.

You may disable or delete cookies through your browser settings at any time, but doing so may impair some features of the Services.

10 · International Users and Data Transfers

SCT may serve clients worldwide. By using the Services, you understand that your information may be processed in the United States or other countries where SCT, its service providers, contractors, or technology vendors operate.

Data protection laws in those countries may differ from the laws in your location. Where personal information is transferred from the United Kingdom, the European Economic Area, or another jurisdiction with comparable data protection law, SCT will rely on appropriate safeguards such as: (a) the UK International Data Transfer Agreement or Addendum; (b) the EU Standard Contractual Clauses; (c) adequacy decisions; or (d) other lawful transfer mechanisms recognised under applicable law.

11 · Data Retention

SCT retains personal information for as long as reasonably necessary to provide the Services, operate the business, maintain records, comply with legal obligations, resolve disputes, enforce agreements, and protect SCT's rights.

Retention periods are determined by reference to the purpose for which the information was collected. As a general matter:

• Active account information is retained for as long as the account is open and for a reasonable period thereafter to facilitate reactivation, dispute resolution, and operational continuity.
• Signed agreements, risk disclosure acknowledgments, methodology disclosure receipts, and Package Selection Forms are retained for the duration of the agreement and for a period thereafter consistent with applicable limitation periods for legal claims.
• Payment, invoice, refund, and transaction records are retained for the period required by tax, accounting, and financial reporting law.
• Support records and communications are retained for as long as needed to handle the matter and for a reasonable period thereafter.
• Information collected for security, fraud prevention, or intellectual property protection purposes may be retained for an extended period to the extent necessary to fulfil those purposes.
• Information necessary to address legal claims, regulatory inquiries, investigations, or enforcement actions may be retained for the duration of those matters and any applicable limitation period thereafter.

Where retention is no longer necessary for any of the foregoing purposes, SCT will delete, anonymise, or otherwise restrict the relevant information. Aggregated or de-identified data that cannot reasonably be associated with an individual may be retained indefinitely for analytics and research purposes.

12 · Security

SCT uses reasonable administrative, technical, and organisational safeguards designed to protect personal information from unauthorised access, misuse, loss, disclosure, alteration, or destruction. These safeguards may include encryption in transit, access controls, monitoring, restricted data environments, and periodic review of security practices.

However, no system is perfectly secure. SCT cannot guarantee that unauthorised access, hacking, data loss, system errors, or security breaches will never occur.

Clients are responsible for keeping their own login credentials, devices, email accounts, two-factor authentication, app access, dashboard access, broker accounts, third-party capital platform accounts, charting accounts, execution-platform accounts, and related platforms secure.

13 · Client Credentials and Sensitive Access Information

SCT does not require trading-account login credentials or execution-platform login credentials as a standard part of onboarding.

If Client voluntarily submits sensitive access information for support or technical assistance, Client authorises SCT to use that information solely for the support purpose requested. SCT may limit access to such information, redact it, delete it after use, or request that Client change passwords after support is complete.

Clients should never send SCT:

• Crypto wallet seed phrases.
• Private keys.
• Unnecessary passwords.
• Sensitive personal information unrelated to SCT's services.
• Any information Client is not authorised to share.

14 · Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information, including the right to:

• Request access to personal information SCT holds about you.
• Request correction of inaccurate information.
• Request deletion of certain information.
• Request restriction of certain processing.
• Object to certain processing.
• Request portability of certain information.
• Withdraw consent where processing is based on consent.
• Opt out of certain marketing or targeted advertising communications.
• Lodge a complaint with a data protection authority where applicable (see Section 19 for UK and EU users).

These rights are not absolute. SCT may decline, defer, or limit a request in defined circumstances permitted by applicable law, including where the request is manifestly unfounded or excessive, where granting the request would conflict with SCT's legal obligations, where granting the request would prejudice the prevention or detection of crime or fraud, where granting the request would interfere with the protection of intellectual property or trade secrets, or where granting the request would adversely affect the rights and freedoms of other persons.

Where SCT declines, defers, or limits a request, SCT will explain the reason to the extent permitted by law and inform you of your right to lodge a complaint with a relevant data protection authority. SCT may require reasonable identity verification before responding to a request and may charge a reasonable fee or refuse the request where the request is manifestly unfounded or excessive.

To make a privacy request, contact SCT using the contact information in Section 22. SCT will respond within the timeframes required by applicable law (for example, one month under UK and EU GDPR, extendable to three months where the request is complex or where multiple requests have been received).

15 · Marketing Communications and Targeted Advertising

SCT may send the following categories of communications:

• Service-related messages, including onboarding updates, support messages, account notices, security alerts, and policy updates. These are necessary for the provision of the Services and you cannot opt out of them while you maintain an active account.
• Marketing and promotional communications, including newsletters, product announcements, research briefs, methodology updates, educational content, and offers. Where applicable law requires opt-in consent for marketing communications (for example, in the United Kingdom, the European Union, and other jurisdictions with similar requirements), SCT will obtain your explicit opt-in before sending these communications.
• Targeted advertising and retargeting communications delivered through advertising platforms (for example, Meta, Google, LinkedIn, X, YouTube, and similar platforms). Where applicable law requires opt-in consent for the use of advertising cookies, pixels, or similar tracking technologies, SCT will obtain your explicit opt-in before enabling targeted advertising in your session.

You may opt out of marketing communications at any time by following the unsubscribe instructions in any marketing message, by adjusting preferences in the dashboard where available, or by contacting SCT support. Opting out of marketing communications does not affect your receipt of service-related communications.

If you opt out of targeted advertising, you may continue to see advertising about SCT or its Services on third-party platforms, but those advertisements will not be targeted to you based on data shared by SCT.

16 · Operational Monitoring and Limits on Expectation of Privacy

To maintain security, prevent abuse, detect fraud, protect intellectual property, comply with legal obligations, and continuously improve the Services, SCT may monitor, log, analyse, and audit activity within the Services. Such monitoring may apply to:

• Activity within the SCT website, app, dashboard, member portal, and support systems.
• Interactions with support staff and automated support tools.
• Software usage patterns, configuration activity, and behavioural analytics within the Services.
• API calls, alert triggers, and routing activity made through SCT infrastructure.
• Metadata generated by your device or browser during access to the Services.

In respect of the activity and metadata described above, you acknowledge that monitoring may be conducted automatically or manually, in real time or retrospectively, and that you should not expect such activity to be private as between you and SCT.

This Section 16 does not limit, override, or constitute a waiver of any data subject right available to you under applicable data protection law, including the rights described in Section 14 and Section 19. SCT will not use monitoring data for purposes that are inconsistent with the lawful bases identified in Section 06 or the purposes identified in Section 05.

17 · Children's Privacy

SCT's services are not intended for children or individuals under the age of majority in their jurisdiction. SCT does not knowingly collect personal information from children. If SCT becomes aware that it has collected personal information from a child without appropriate consent, SCT will delete that information.

18 · Third-Party Links and Platforms

The SCT website, app, dashboard, or support materials may reference or link to third-party platforms, including the supported charting and execution platforms, brokers, third-party capital platforms, payment processors, communication tools, or other services.

SCT is not responsible for the privacy practices, security practices, terms, rules, or decisions of any third-party platform. Clients should review the privacy policies and terms of any third-party platform they use.

19 · UK and EU Data Subjects

If you are located in the United Kingdom, the European Union, or the European Economic Area, the following additional provisions apply to you. SCT is the controller of personal information processed in connection with the Services.

19.1 Your UK and EU Rights

You have the following rights under the UK General Data Protection Regulation, the EU General Data Protection Regulation, or equivalent applicable law, in addition to the rights described in Section 14:

• Right of access (Article 15).
• Right to rectification (Article 16).
• Right to erasure / "right to be forgotten" (Article 17).
• Right to restriction of processing (Article 18).
• Right to data portability (Article 20).
• Right to object to processing, including processing based on legitimate interests and processing for direct marketing (Article 21).
• Right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects (Article 22).
• Right to withdraw consent at any time, where processing is based on consent (Article 7).

19.2 Right to Lodge a Complaint

If you believe SCT has not handled your personal information in accordance with applicable law, you have the right to lodge a complaint with a supervisory authority. For UK users, the supervisory authority is the Information Commissioner's Office (ICO):

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, United Kingdom. Website: https://ico.org.uk. Helpline: 0303 123 1113.

For EU users, you may lodge a complaint with the supervisory authority in your country of residence, place of work, or place of the alleged infringement. A list of EU supervisory authorities is available at https://edpb.europa.eu.

19.3 International Transfers

Personal information of UK and EU data subjects may be transferred outside the UK or EEA in accordance with Section 10. Where required, SCT relies on the UK International Data Transfer Agreement or Addendum, the EU Standard Contractual Clauses, or another lawful transfer mechanism.

19.4 Automated Decision-Making

SCT does not make decisions based solely on automated processing that produce legal or similarly significant effects on you without human review. Where any such processing is introduced in the future, you will be informed and provided with the rights required by applicable law.

UK / EU Representative

Where SCT is required under Article 27 of the UK or EU GDPR to designate a representative in the United Kingdom or European Union, the representative's contact details will be published here and made available on request. [To be confirmed with counsel and completed before publication.]

20 · No Sale of Personal Information

SCT does not sell personal information for money. SCT does not share personal information with third parties for their independent marketing purposes without your consent where required by applicable law.

Personal information may be shared in connection with a sale of company, merger, acquisition, financing, restructuring, or business transfer as described in Section 08.

21 · Changes to This Privacy Policy

SCT may update this Privacy Policy from time to time. If changes are material, SCT may provide notice through the website, app, dashboard, email, or another reasonable method. The updated Privacy Policy will be effective when posted or otherwise made available, unless a later effective date is stated.

22 · Contact Information

For privacy questions or requests, contact SCT at:

SCT Consulting LLC

Email: support@sctsuite.com

Website: sctsuite.com