PRIVACY POLICY

1. Introduction

TGM Ventures, Inc., a Washington State corporation ("Company", "we", "us", or "our"), operates the DrawdownAlerts website and services (collectively, the "Service"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Service.

BY USING THE SERVICE, YOU CONSENT TO THE DATA PRACTICES DESCRIBED IN THIS POLICY. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, PLEASE DO NOT ACCESS OR USE THE SERVICE.

We reserve the right to make changes to this Privacy Policy at any time. We will alert you about any changes by updating the "Last Updated" date. Your continued use of the Service after any changes indicates your acceptance of the updated Privacy Policy.

2. Information We Collect

2.1 Personal Information You Provide

We collect information that you voluntarily provide when you:

• Register for an Account: Email address, name, password (encrypted)
• Subscribe to Paid Plans: Billing information processed through Stripe (we do not store complete payment card information)
• Use the Service: Stock symbols you monitor, alert preferences, portfolio data
• Contact Us: Any information you include in correspondence with us

2.2 Information Automatically Collected

When you access the Service, we automatically collect certain information, including:

• Usage Data: Pages visited, features used, time spent on the Service, links clicked
• Device Information: IP address, browser type and version, device type, operating system, unique device identifiers
• Location Data: General geographic location based on IP address
• Cookies and Tracking Technologies: See Section 4 below
• Log Data: Access times, error logs, referring/exit pages

2.3 Information from Third Parties

We may receive information from third-party services you connect to your account:

• Authentication Providers: If you sign in using a third-party service (e.g., Google), we receive basic profile information
• Payment Processors: Stripe provides us with payment status and limited billing information
• Market Data Providers: Stock price and market data from our data suppliers
• Analytics Services: Aggregate usage statistics from analytics platforms

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 To Provide and Maintain the Service

• Create and manage your account
• Process and track your monitoring requests
• Send you alert notifications when drawdown thresholds are met
• Display stock data, charts, and metrics
• Process subscription payments
• Provide customer support

3.2 To Improve and Develop the Service

• Analyze usage patterns and trends
• Conduct research and development
• Debug and fix technical issues
• Test new features and functionality
• Enhance user experience and interface design

3.3 For Communication

• Send you service announcements and updates
• Respond to your inquiries and support requests
• Send you promotional communications (you may opt out)
• Request feedback or participation in surveys
• Notify you of changes to our policies or terms

3.4 For Security and Legal Compliance

• Detect and prevent fraud, abuse, and security incidents
• Monitor and analyze security threats
• Enforce our Terms of Service
• Comply with legal obligations and law enforcement requests
• Protect our rights, property, and safety, and those of our users

3.5 For Business Operations

• Process and manage subscriptions and billing
• Conduct business analysis and reporting
• Manage our relationship with service providers
• Facilitate corporate transactions (mergers, acquisitions)

4. Cookies and Tracking Technologies

4.1 What Are Cookies

Cookies are small text files stored on your device that help us provide and improve the Service. We use both session cookies (which expire when you close your browser) and persistent cookies (which remain until deleted or expired).

4.2 Types of Cookies We Use

4.3 Third-Party Cookies

We may allow third-party service providers to place cookies on your device for the purposes described above. These third parties include:

• Google Analytics (usage analytics)
• Stripe (payment processing)
• Firebase (authentication and hosting)

4.4 Managing Cookies

Most web browsers are set to accept cookies by default. You can choose to set your browser to remove or reject cookies, but this may affect the availability and functionality of the Service. For more information on how to manage cookies, visit your browser's help documentation.

5. How We Share Your Information

We do not sell your personal information to third parties. We may share your information in the following circumstances:

5.1 Service Providers

We share information with third-party service providers who perform services on our behalf, including:

• Payment Processing: Stripe, Inc. processes all payment transactions. See Stripe's Privacy Policy at stripe.com/privacy
• Cloud Hosting: Google Firebase provides infrastructure, authentication, and data storage services
• Email Service: Email delivery services for sending alerts and notifications
• Analytics: Google Analytics and other analytics providers to understand Service usage
• Market Data: Financial data providers supply stock market information

These service providers are contractually obligated to use your information only for the purposes of providing services to us and are required to maintain the confidentiality and security of your information.

5.2 Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of assets, or transition of service to another provider, your information may be transferred as part of that transaction. We will provide notice before your information is transferred and becomes subject to a different privacy policy.

5.3 Legal Requirements and Safety

We may disclose your information if required to do so by law or in response to valid requests by public authorities, including to:

• Comply with legal obligations, court orders, or legal process
• Respond to lawful requests from law enforcement or government agencies
• Protect and defend our rights or property
• Prevent or investigate possible wrongdoing, fraud, or security issues
• Protect the personal safety of users or the public

5.4 Aggregated or De-identified Data

We may share aggregated or de-identified information that cannot reasonably be used to identify you. This includes statistics about Service usage, industry trends, and market research.

5.5 With Your Consent

We may share your information for any other purpose with your consent or at your direction.

6. Important Disclaimers

7. Data Security

We implement appropriate technical and organizational security measures designed to protect your information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures include:

• Encryption of data in transit using SSL/TLS protocols
• Encryption of sensitive data at rest
• Secure authentication and access controls
• Regular security assessments and monitoring
• Restricted employee access to personal information on a need-to-know basis
• Secure payment processing through PCI-compliant providers

HOWEVER, NO SECURITY MEASURES ARE PERFECT OR IMPENETRABLE. WE CANNOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR INFORMATION. ANY TRANSMISSION OF INFORMATION IS AT YOUR OWN RISK.

If we become aware of a data breach that compromises your personal information, we will notify you in accordance with applicable law.

8. Data Retention

We retain your personal information for as long as necessary to provide the Service and fulfill the purposes described in this Privacy Policy. Our retention periods are based on:

• The length of time you maintain an active account
• Whether you have an active subscription or outstanding financial obligations
• Legal, regulatory, tax, or accounting requirements
• The need to resolve disputes or enforce our agreements
• Legitimate business purposes such as fraud prevention and security

When we no longer have a legitimate business need to process your information, we will delete or anonymize it. If deletion is not possible (for example, because information has been stored in backup archives), we will securely store and isolate your information from further processing until deletion is possible.

After account deletion, we may retain certain information in aggregated or anonymized form that cannot be used to identify you personally.

9. Your Privacy Rights

Depending on your location and applicable laws, you may have certain rights regarding your personal information:

9.1 All Users

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information (subject to legal obligations)
• Opt-Out of Marketing: Unsubscribe from promotional emails using the unsubscribe link or by contacting us
• Account Settings: Update your account information and preferences through your account settings

9.2 California Residents (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

• Right to Know: Request disclosure of personal information we collected, used, or disclosed in the past 12 months
• Right to Delete: Request deletion of your personal information (subject to exceptions)
• Right to Correct: Request correction of inaccurate personal information
• Right to Opt-Out: Opt out of the sale or sharing of personal information (we do not sell personal information)
• Right to Limit Use: Limit the use and disclosure of sensitive personal information
• Non-Discrimination: You will not receive discriminatory treatment for exercising your privacy rights

We do not sell personal information as defined by the CCPA. We do not knowingly sell personal information of minors under 16.

9.3 European Residents (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have rights under the General Data Protection Regulation (GDPR):

• Access: Obtain confirmation of whether we process your data and receive a copy
• Rectification: Request correction of inaccurate data
• Erasure: Request deletion of your data (right to be forgotten)
• Restriction: Request restriction of processing in certain circumstances
• Data Portability: Receive your data in a structured, machine-readable format
• Object: Object to processing based on legitimate interests or for direct marketing
• Withdraw Consent: Withdraw consent for processing based on consent
• Lodge a Complaint: File a complaint with your local data protection authority

Note: The Service is primarily intended for U.S. residents. If you are located outside the United States, your information will be transferred to and processed in the United States, which may have different data protection laws than your jurisdiction.

9.4 Exercising Your Rights

To exercise any of these rights, please contact us using the information in Section 16. We may require verification of your identity before processing your request. We will respond to verified requests within the timeframes required by applicable law (typically 30-45 days).

You may designate an authorized agent to make requests on your behalf. The agent must provide proof of authorization and we may require you to verify your identity directly with us.

10. Children's Privacy

The Service is not intended for children under the age of 18. We do not knowingly collect personal information from children under 18. If you are under 18, do not use the Service or provide any information to us.

If we learn that we have collected personal information from a child under 18 without verification of parental consent, we will delete that information as quickly as possible. If you believe we might have information from or about a child under 18, please contact us immediately.

BY USING THE SERVICE, YOU REPRESENT THAT YOU ARE AT LEAST 18 YEARS OLD.

11. International Data Transfers

The Company is based in the United States, and your information is processed and stored in the United States. If you are accessing the Service from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States and other countries where our service providers operate.

The United States and other jurisdictions may have different data protection laws than your country of residence. By using the Service, you consent to the transfer of your information to the United States and other countries.

For European residents: We ensure that any international transfers comply with applicable data protection laws through appropriate safeguards such as standard contractual clauses.

12. Do Not Track Signals

Some web browsers have a "Do Not Track" ("DNT") feature that signals to websites that you do not want your online activities tracked. Currently, there is no uniform standard for recognizing and implementing DNT signals, and the Service does not respond to DNT browser signals.

However, you can manage cookie preferences through your browser settings as described in Section 4.4.

13. Third-Party Websites and Services

The Service may contain links to third-party websites or integrate with third-party services. This Privacy Policy applies only to the Service. We are not responsible for the privacy practices of third-party websites or services.

We encourage you to read the privacy policies of any third-party websites or services before providing them with your personal information. Third-party services we integrate with include:

• Stripe: Payment processing - see Stripe's Privacy Policy at stripe.com/privacy
• Google/Firebase: Authentication, hosting, analytics - see Google's Privacy Policy at policies.google.com/privacy
• Market Data Providers: Stock market information from third-party data suppliers

14. Email Communications and Opt-Out

We send several types of email communications:

• Transactional Emails: Account-related notifications, alert notifications, billing statements, password resets (you cannot opt out of these essential communications)
• Service Updates: Important updates about the Service, changes to terms or policies
• Marketing Emails: Promotional content, newsletters, feature announcements (you can opt out)

To opt out of marketing emails, click the "unsubscribe" link at the bottom of any marketing email or update your preferences in your account settings. Please note that even if you opt out of marketing emails, we will still send you transactional and service-related communications.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will post the updated Privacy Policy on this page and update the "Last Updated" date.

If we make material changes to how we treat your personal information, we will notify you by email (if you have provided an email address) and/or by posting a prominent notice on the Service prior to the changes taking effect.

We encourage you to review this Privacy Policy periodically. Your continued use of the Service after any changes indicates your acceptance of the updated Privacy Policy.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us through our website.

We will respond to your inquiry within a reasonable timeframe. For data subject access requests and privacy rights inquiries, we will respond within the timeframes required by applicable law.

17. Additional Information for Specific Jurisdictions

17.1 Nevada Residents

Nevada residents have the right to opt out of the sale of certain personal information to third parties. We do not sell your personal information as defined by Nevada law. If you have questions, please contact us using the information above.

17.2 Virginia, Colorado, Connecticut, and Utah Residents

If you are a resident of Virginia, Colorado, Connecticut, or Utah, you may have additional rights under your state's consumer privacy laws, including the right to access, correct, delete, and obtain a copy of your personal information, as well as the right to opt out of targeted advertising and the sale of personal information.

To exercise these rights, please contact us using the information in Section 16. We do not sell personal information or use personal information for targeted advertising as defined by these state laws.