Privacy Policy

Adaptive Investing · Effective October 9, 2026 · Last updated October 9, 2026

1. Introduction

Adaptive Investing ("we," "us," or "our") operates the Adaptive Investing platform (the "Service"), an educational stock-scoring tool. The Service is operated by an individual based in California, United States. This Privacy Policy explains what limited information we process when you use the Service and the choices you have.

This policy describes the Service as it operates today: a free, fully anonymous tool with no user accounts and no login. Paid tiers, accounts, payments, and AI-assisted analysis are planned but not yet live; when they launch, we will update this policy (for example, to add a payment processor or an AI provider) before those features collect or share any new information.

2. Information We Collect

2.1 What we do NOT collect

To use the Service you do not provide, and we do not collect, any of the following: names, email addresses (except the optional waitlist and any email you choose to send us — see Section 2.3), passwords or account credentials, or payment-card details. The Service currently has no user accounts and no authentication.

2.2 Information processed automatically

To operate and protect the Service, we process a small amount of technical data:

• IP address: Your IP address is used transiently, in server memory, to apply short per-minute rate limits. When you run a scan, it is also used as a per-IP backstop for the free daily scan quota (so one person cannot evade the limit by clearing cookies). For that quota record we do not store your IP address itself: we store only a keyed hash (HMAC) of it, computed with a secret key held on our server. It is not used to identify you personally or to build a profile.
• A single functional cookie (sse_device): When live scoring is available, our server sets one first-party cookie containing a random identifier so we can count your free daily scans per browser. It holds no personal information. It is set or refreshed when you open the app and each time a scan is recorded, and it lasts 7 days from the last time it was set or refreshed. It is marked HttpOnly, Secure, and SameSite=Lax, and is used only for the free scan quota. It is not an advertising or cross-site tracking cookie. While live scoring is paused, no quota cookie is needed: we do not set it, and if your browser still has one, our server deletes it on your next visit. Older sse_device cookies, issued before October 9, 2026 with a longer lifetime, are cleared or replaced on your next visit. See Section 5.
• Scan records: When you run a scan, we record the sse_device identifier, the keyed hash of your IP address, the stock ticker, and a timestamp. These records exist only to enforce the scan quota and are deleted after about 24 hours (Section 6).
• Hosting and network logs: Our hosting provider (Railway) and our DNS and network provider (Cloudflare) keep standard request logs, which can include IP addresses, the page or API path requested (which may contain a stock ticker), and the time, for reliability and security. Those logs are kept under each provider's own retention, typically up to about 30 days.
• Library requests: The app page loads the open-source JavaScript libraries React and Babel from unpkg.com. When your browser fetches these files, unpkg receives your IP address and browser user agent. Our web fonts are served from our own domain. See Section 4.

2.3 Information you choose to provide

• Waitlist email (optional): If you join our waitlist, you do so on a page hosted by our newsletter provider, Beehiiv, which collects your email address. We do not store waitlist emails on our own servers. Your email stays on the list until you unsubscribe. See Section 4.
• Emails you send us: If you email us (for example, to report an error or a security issue, or to make a privacy request), we receive your email address and message and keep them as long as needed to respond and to keep a record of the matter.
• Saved analysis (premium features, not currently available to the public): Saved questionnaires and watchlists are stored as records keyed by stock ticker and contain no personal identifiers (no name, email, IP, or account id).

3. How We Use Information

We use the limited data described above to:

• Provide the Service — generate stock scores and analyses in response to your searches, when live scoring is available;
• Enforce the free-tier daily scan quota fairly across users;
• Apply rate limits and detect or prevent abuse, fraud, and unauthorized access;
• Maintain the security and reliability of the Service;
• Respond to messages you send us;
• Comply with applicable law and respond to lawful requests.

We do not: sell or rent your data; serve advertising or use advertising cookies or pixels; use analytics services; build advertising or cross-site tracking profiles; or use your searches to train AI models. We do not use information about you to personalize scores: scores come from a fixed rubric, the same rubric for every company, and are identical for every visitor, and we do not answer individual investment questions.

4. Service Providers (Sub-processors)

We rely on a small set of third parties to operate the Service. We describe data providers by category. When live scoring is available, the stock tickers you search are sent to financial-data providers as a necessary part of generating a score; these providers receive the ticker only, not personal data about you.

AI processing is not active. AI-assisted analysis of qualitative categories is planned but not running, and no data is sent to Anthropic or any other AI provider today. The code that would call an AI provider is disabled unless we explicitly enable it. If we enable it, we will update this policy and the table above before any data is shared with an AI provider.

If we add or change a data provider, it will receive only a ticker or company name, never your personal information, and we will update the table above.

We may also disclose information if required by law or valid legal process, or to protect the rights, property, or safety of Adaptive Investing, our users, or the public. If we are ever involved in a merger or acquisition, we will provide notice before any information becomes subject to a different policy.

5. Cookies and Tracking

We use at most one cookie: the first-party sse_device functional cookie described in Section 2.2. Its sole purpose is to meter the free daily scan quota per browser. It is strictly necessary for that feature, contains no personal data, and is not used for advertising. While live scoring is paused we set no cookie at all, and we delete any existing sse_device cookie on your next visit.

We do not use any usage analytics, advertising cookies, advertising pixels, or third-party tracking pixels — no Google Analytics, no advertising or cross-site trackers.

Because the only cookie is strictly necessary and we set no analytics or advertising cookies, no cookie-consent banner is required. You can clear the sse_device cookie at any time through your browser settings; doing so simply resets your free-scan count.

5.1 Do Not Track and Global Privacy Control

Some browsers can send a "Do Not Track" (DNT) or Global Privacy Control (GPC) signal. We do not track visitors across third-party websites over time, and we do not sell or share personal information, so there is no tracking for these signals to switch off. The Service works the same way whether or not your browser sends them.

5.2 Collection by third parties across sites

We do not allow third parties to collect personal information about your online activities over time and across different websites through our Service, with one limited exception: when your browser loads the JavaScript libraries used by the app page from unpkg.com, that service receives your IP address and browser user agent, as described in Section 4. The waitlist is on Beehiiv's own page and is governed by Beehiiv's privacy policy.

6. Data Retention

Because the Service is anonymous, we hold very little data about you, and we hold it only briefly:

• Scan quota records (the sse_device identifier, a keyed hash of your IP address, the ticker, and a timestamp) are stored in a small server-side database solely to enforce the free daily scan limit. They are kept only for the rolling quota window and are deleted automatically after about 24 hours.
• Rate-limit counters are held in server memory for a few minutes and are never written to disk.
• The sse_device cookie, when live scoring is available, expires in your browser 7 days after it was last set or refreshed (it is set or refreshed when you open the app and each time a scan is recorded). While live scoring is paused, our server deletes any existing sse_device cookie on your next visit. Older cookies, issued before October 9, 2026 with a longer lifetime, are cleared or replaced on your next visit.
• Hosting and network logs are kept by those providers under their own retention, typically up to about 30 days.
• Waitlist email addresses are kept by Beehiiv until you unsubscribe.
• Emails you send us are kept as long as needed to respond and to keep a record of the matter.

We do not build profiles and do not maintain long-term, user-identifiable activity logs.

7. Your Rights

Because we operate anonymously and hold no account, name, or contact information about you (other than transient technical data, and — if you opted in — your waitlist email held by Beehiiv), in most cases there is little or no personal data for us to look up, export, or delete. You can nonetheless exercise the rights below.

7.1 All users

• Access / deletion: Request access to or deletion of any personal data we hold about you by emailing contact@adaptive-investing.com.
• Reset your local identifier: Clear the sse_device cookie via your browser at any time.
• Unsubscribe from the waitlist: Use the unsubscribe link in any waitlist email, or contact us, to have Beehiiv remove your email.

7.2 European users (GDPR)

The Service is intended for persons in the United States and is not directed at persons in the European Economic Area or the United Kingdom (see our Terms of Service). If you nonetheless use it from the European Economic Area, United Kingdom, or Switzerland, you have the rights of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), portability (Art. 20), and objection (Art. 21).

Legal bases: We rely on legitimate interests (operating, securing, and rate-limiting the Service) for the technical data in Section 2.2, and on consent for the optional waitlist email. You may withdraw consent at any time and may lodge a complaint with your local supervisory authority. Data may be processed in the United States by the providers listed in Section 4.

7.3 California residents (CCPA/CPRA)

The categories of personal information we process are identifiers (the sse_device cookie value, a keyed hash of your IP address, and the IP address held transiently in server memory and in our providers' request logs) and internet/electronic activity (tickers scanned). We collect them directly from your browser and process them solely to operate and secure the Service. We keep them for the periods in Section 6.

• We do not sell or share your personal information, and we do not use it for cross-context behavioral advertising. We have not sold or shared personal information in the preceding 12 months. There is therefore no "Do Not Sell or Share" action needed — but we state this expressly for clarity.
• We do not collect sensitive personal information.
• You have the right to know, the right to correct, and the right to delete the personal information we hold; contact us at contact@adaptive-investing.com.
• We will not discriminate against you for exercising your privacy rights.
• "Shine the Light" (Cal. Civ. Code § 1798.83): we do not disclose personal information to third parties for their own direct-marketing purposes.

8. Children's Privacy

The Service is intended for adults (18+) and is not directed at children under 13 (or under 16 in the EEA). We do not knowingly collect personal information from children. If you believe a child has provided us information, contact us and we will delete it.

9. Security

We use HTTPS/TLS for all traffic and apply reasonable technical measures to protect the limited data we process. No method of transmission or storage is perfectly secure, and we cannot guarantee absolute security. We will notify affected users of a qualifying data breach as required by law. To report a security vulnerability, see our Vulnerability Disclosure Policy.

10. Changes to This Policy

We may update this Privacy Policy from time to time — for example, when accounts, payments, or new analytics are introduced. We will post the updated policy here and revise the "Last updated" date. If a change is material — for example, collecting a new kind of personal information or sharing it with a new kind of recipient — we will post a dated notice on the Service, and email waitlist subscribers where practical, at least 14 days before the change takes effect. A change applies only going forward.

11. Contact Us

For privacy questions or to exercise your rights, contact us at:

Adaptive Investing (operated by an individual based in California)
Email: contact@adaptive-investing.com

We aim to respond to privacy requests within 30 days.

This Privacy Policy was last updated on October 9, 2026. This document is provided in good faith and is not a substitute for advice from a licensed attorney.