QVL Models

Privacy Policy

Draft Notice

This document is a structured starting draft prepared for QVL Models, Inc. and has not been reviewed by a licensed attorney. It must be reviewed by qualified counsel — including for compliance with PIPEDA (Canada) and applicable U.S. state privacy law — before being relied upon with real clients.

1. Information We Collect

When you register, we collect your name, email address, phone number (optional), and country. If you connect a brokerage account, we receive connection metadata (provider, account type, connection status) from that provider. We also collect usage data (such as login activity) to operate and improve the Service.

2. How Encryption Protects Your Data

Sensitive data related to your connected brokerage accounts — including access tokens, holdings, transaction history, and account balances — is encrypted at rest using industry-standard encryption, with encryption keys managed through Azure Key Vault, a dedicated cloud key-management service. Access to this encrypted data is restricted and logged.

3. How We Use Your Information

We use your information to provide the Service, process payments, communicate with you about your account, and meet legal and compliance obligations. We do not sell your personal information.

4. Third-Party Sharing

We share information with service providers who help us operate the Service: brokerage connection providers (such as Plaid or SnapTrade) when you choose to connect an account, our payment processor (Stripe) for billing (QVL does not store your raw card number), and our email provider for account communications. We do not share your information with third parties for their own marketing purposes.

5. Data Retention

We retain your information for as long as your account is active and as needed to comply with legal, tax, and regulatory obligations after account closure.

6. Your Rights

You may request access to, correction of, or deletion of your personal information by contacting privacy@qvlmodels.com.

Additional Rights for Canadian Clients:

Under the Personal Information Protection and Electronic Documents Act (PIPEDA), you have the right to access the personal information we hold about you and to challenge its accuracy.

Additional Rights for U.S. Clients:

Depending on your state of residence, you may have additional rights to access, delete, or opt out of certain uses of your personal information under applicable state privacy law.

7. Cookies and Analytics

We use cookies and similar technologies to keep you signed in and to understand how the Service is used.

8. International Data Transfer

Your information is processed and stored on cloud infrastructure that may be located outside your country of residence. We take steps to ensure your information continues to receive an appropriate level of protection wherever it is processed.

9. Children's Privacy

The Service is not directed at, and is not intended for use by, anyone under the age of 18.

10. Changes to This Policy

We may update this Privacy Policy from time to time. If a change is material, we will ask you to re-accept the updated policy.

11. Contact

Questions about this Privacy Policy can be sent to privacy@qvlmodels.com.