Privacy Policy

Last Updated: March 18, 2025

Introduction

Welcome to the AI Agent Backtesting Platform ("Platform," "we," "our," or "us"), operated by Spooky Labs, Inc. ("Spooky Labs"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our backtesting platform service for submitting and evaluating trading algorithms.

We are committed to protecting your personal information and your right to privacy. If you have any questions about this Privacy Policy, please contact us at privacy@spookylabs.ai.

Information We Collect

Personal Information

We may collect personal information that you voluntarily provide to us when you:

  • Create an account
  • Submit trading algorithms/agents
  • Participate in the platform leaderboard
  • Contact us with inquiries
  • Subscribe to our newsletter

This information may include:

  • Name and contact information (email address, username)
  • Account credentials
  • Professional information (if provided)
  • Payment information (processed through secure third-party payment processors)
  • Any other information you choose to provide

Usage Data

We automatically collect certain information when you visit, use, or navigate the Platform:

  • Technical information (IP address, browser type, device information)
  • Usage patterns (pages visited, features used, time spent)
  • Performance data related to your submitted algorithms
  • Error reports

Algorithm and Code Data

When you submit trading algorithms to our Platform:

  • We collect and store the code and associated files you submit
  • We process metrics and performance results generated by your algorithms
  • We may analyze code for security, compliance, and performance optimization

How We Use Your Information

We use your information for the following purposes:

  • Provide, operate, and maintain the Platform
  • Process and manage your account
  • Facilitate algorithm evaluation and backtesting
  • Generate and display performance metrics and leaderboards
  • Communicate with you regarding your account or inquiries
  • Send you technical notices, updates, and security alerts
  • Improve and optimize the Platform
  • Detect, prevent, and address technical or security issues
  • Comply with legal obligations

Legal Bases for Processing (EU Users)

For users in the European Union, we process your personal information based on the following legal grounds:

  • Performance of our contract with you
  • Your consent
  • Our legitimate interests (operating and improving our services)
  • Compliance with legal obligations

How We Share Your Information

We may share your information with:

  • Service Providers: Third-party vendors who help us operate our business (hosting providers, payment processors, analytics services)
  • Business Partners: With your consent, we may share information with partners offering complementary services
  • Legal Requirements: When required by law, court order, or governmental authority
  • Business Transfers: In connection with a merger, acquisition, or sale of all or part of our assets
  • With Your Consent: In other circumstances where we seek your permission

We do NOT sell your personal information to third parties.

Data Security

We implement appropriate technical and organizational measures to protect your personal information:

  • Secure Docker containers for code execution
  • Encryption of data in transit and at rest
  • Access controls and authentication mechanisms
  • Regular security audits

While we strive to protect your information, no method of transmission over the Internet or electronic storage is 100% secure.

Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law. We may retain anonymized or aggregated data indefinitely.

Your Privacy Rights

For European Union Residents (GDPR)

If you are a resident of the European Union, you have the following rights:

  • Right to access your personal information
  • Right to rectification of inaccurate information
  • Right to erasure ("right to be forgotten")
  • Right to restrict processing
  • Right to data portability
  • Right to object to processing
  • Right to withdraw consent
  • Right to lodge a complaint with a supervisory authority

For California Residents (CCPA/CPRA)

If you are a California resident, you have the following rights:

  • Right to know what personal information is collected, used, shared, or sold
  • Right to delete personal information held by us (with exceptions)
  • Right to opt-out of the sale of personal information
  • Right to non-discrimination for exercising your rights
  • Right to correct inaccurate personal information
  • Right to limit use and disclosure of sensitive personal information

For All Users

Regardless of your location, you can:

  • Update or delete your account information by logging into your account settings
  • Opt-out of marketing communications via the unsubscribe link in our emails
  • Contact us to exercise your applicable privacy rights

To exercise your rights, please contact us at privacy@spookylabs.ai.

Children's Privacy

Our Platform is not intended for children under 16 years of age. We do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided us with personal information, please contact us.

Third-Party Links and Services

Our Platform may contain links to third-party websites, services, or content that are not owned or controlled by us. This Privacy Policy does not apply to those third-party services. We recommend reviewing the privacy policies of any third-party services you access.

International Data Transfers

Your information may be transferred to, stored, and processed in countries other than your country of residence. When we transfer data internationally, we implement appropriate safeguards in accordance with applicable law.

Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last Updated" date.

Contact Us

If you have questions about this Privacy Policy or our privacy practices, please contact us at:

Email: privacy@spookylabs.ai
Address: Spooky Labs, Inc., Seattle, WA, USA

Your Consent

By using our Platform, you consent to our Privacy Policy and agree to its terms. If you do not agree with our policies and practices, please do not use our Platform. Your continued use of the Platform following the posting of changes to this Privacy Policy will be deemed your acceptance of those changes.