Privacy

1. Who we are

ViceWire Pty Ltd ("ViceWire", "we", "us", "our") operates the website vicewire.ai and related services that turn global news into structured, machine-readable signals for traders and research teams (the Services).

For the purposes of applicable data protection laws, ViceWire acts as a data controller in relation to personal data we collect and determine the purposes and means of processing.

2. Scope and legal frameworks

This Privacy Policy explains how we collect, use, disclose and protect personal data when you:

• visit or interact with our website;
• contact us (for example by email, form or support request);
• subscribe to updates, newsletters or waitlists; or
• create an account or use any account-based features we may offer (for example, saved preferences or custom settings).

We aim to handle personal data in line with:

• The Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs);
• The EU General Data Protection Regulation (GDPR);
• TheUK GDPR and UK Data Protection Act 2018;
• The California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA); and
• The Privacy and Electronic Communications Regulations 2003 (PECR) for certain electronic communications.

If there is any conflict between this Policy and mandatory local law, the latter will prevail.

3. Personal data we collect

The personal data we collect depends on how you interact with us. We may collect:

3.1. Information you provide directly

For example:

• Contact and enquiry data
  • Name, email address, organisation, role, and the content of your message when you contact us or join a waitlist.
• Account and profile data
  • If you create an account (when available): login identifiers, display name, preferences, saved settings or other configuration you choose to store.
• Support and communications data
  • Messages you send to support, feedback you provide, and any attachments or supplementary information you choose to share.

3.2. Information collected automatically

When you visit our website or interact with the Services, we may automatically collect:

• Device and browser information (e.g. IP address, browser type and version, operating system);
• Usage data (e.g. pages viewed, links clicked, time spent, approximate geolocation at city or region level);
• Technical logs and diagnostics (e.g. error logs, performance metrics).

This data is typically collected via cookies, local storage, pixels or similar technologies. See Section 5 (Cookies & analytics) for more detail.

3.3. Information from third parties

We may receive personal data from:

• Service providers and partners
  For example, analytics services, infrastructure providers, security tools or communication services that help operate and secure the Services.
• Authentication providers (if enabled)
  If we allow sign-in via third-party identity providers (e.g. OAuth), we may receive identifiers and basic profile information from them, in accordance with your settings with that provider.
• Publicly available sources
  Where legally permitted (for example, to verify business contact details).

3.4. TradingView charts and usage data

Our website does embed or integrate TradingView's Advanced Charting Library and related APIs. When you interact with TradingView charts:

• TradingView may collect anonymised or aggregated technical and usage data relating to the use and performance of their charting components.
• This usage data is collected and processed by TradingView, Inc. under their own terms and privacy policy.
• We do not control how TradingView processes such data and encourage you to review their privacy policy when using TradingView features.

4. How we use personal data and legal bases

We use personal data only where we have a legal basis to do so. Depending on your location, that may include:

4.1. Providing and operating the Services

Examples

• Operating and maintaining our website and any interactive features;
• Responding to your enquiries, feedback and support requests;
• Creating and managing user accounts and preferences (where available);
• Providing you with information or content you request.

Legal basis

• Performance of a contract or steps taken at your request before entering into a contract (e.g. providing the Services, handling support); and/or
• Our legitimate interests in operating and improving the Services.

4.2. Improving and developing the Services

Examples

• Monitoring usage patterns and performance to improve stability, speed and usability;
• Debugging issues, preventing abuse and improving security;
• Analysing aggregated usage metrics to inform product decisions.

Legal basis

Our legitimate interests in understanding how the Services are used, improving them and ensuring security and reliability.

Where required, we implement measures such as data minimisation and aggregation to balance our interests with your rights.

4.3. Communications and marketing

Examples

• Sending you service-related messages (e.g. important updates, security notices);
• Sending you newsletters, announcements or product updates where you have subscribed.

Legal basis

• Our legitimate interests in keeping users informed of material service changes or issues; and
• Your consent, where required by law (for example, for certain electronic marketing under PECR or local email marketing rules).

You can opt out of marketing at any time by using the unsubscribe link in emails or contacting us directly. Service-critical messages may still be sent.

4.4. Legal, compliance and risk management

Examples

• Complying with legal obligations (e.g. record-keeping, responding to lawful requests);
• Enforcing our Terms of Service and other agreements;
• Protecting our rights, privacy, safety or property, and/or that of our users or others.

Legal basis

• Compliance with legal obligations; and
• Our legitimate interests in protecting our business and users.

5. Cookies and analytics

We may use cookies, local storage and similar technologies to:

• enable core site functionality;
• remember preferences; and
• collect aggregate analytics about how the Services are used.

Where required by law (for example, in the EU/UK), we will:

• request your consent for non-essential cookies and analytics; and
• provide you with options to manage or withdraw consent.

You can also control cookies via your browser settings, though disabling certain cookies may affect functionality.

6. How we share personal data

We do not sell personal information or share it for cross-context behavioural advertising as those terms are used in the CCPA/CPRA.

We may share personal data in the following limited circumstances:

6.1. Service providers (processors)

We engage carefully selected third-party service providers to help us operate the Services, such as:

• cloud hosting and infrastructure;
• analytics and performance monitoring;
• email delivery and support tools;
• authentication and security tooling (if enabled).

These providers process personal data on our instructions and are bound by contractual obligations to protect it and not use it for their own purposes.

6.2. TradingView

When you use TradingView charts embedded on our website:

• TradingView acts as an independent controller of certain technical and usage data relating to the charting components; and
• TradingView processes that data in line with its own terms and privacy policy.

We do not control TradingView's processing and are not responsible for their independent handling of personal data.

6.3. Business transfers

If we are involved in a merger, acquisition, restructuring or sale of assets, personal data may be transferred as part of that transaction, subject to confidentiality safeguards and, where required, notification to affected individuals.

6.4. Legal and regulatory

We may disclose personal data where we believe in good faith that such disclosure is reasonably necessary to:

• comply with applicable law, regulation, legal process or governmental request;
• enforce our agreements or protect our rights; or
• protect the safety of any person.

7. International data transfers

We may process and store personal data in Australia, United States, and in other countries where we or our service providers operate.

Where personal data is transferred from the UK or EEA to a country that is not subject to an adequacy decision:

• we will rely on appropriate safeguards, such as Standard Contractual Clauses (SCCs) or equivalent mechanisms; and
• we will take steps to ensure that your personal data continues to benefit from a level of protection essentially equivalent to that in the originating jurisdiction.

8. Data retention

We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, including:

• for as long as we provide the Services to you or maintain an ongoing relationship;
• as required by law; or
• as needed to resolve disputes, enforce our agreements and protect our rights.

When personal data is no longer required, we will take reasonable steps to delete or anonymise it.

9. Data security

We use technical and organisational measures designed to protect personal data against unauthorised access, disclosure, alteration or destruction. These may include:

• encryption in transit and at rest where appropriate;
• access controls and authentication;
• logging and monitoring of production systems;
• regular review of infrastructure and security posture.

However, no method of transmission or storage is completely secure. You use the Services at your own risk, and you are responsible for choosing secure passwords and keeping your credentials confidential.

10. Your rights

Your privacy rights depend on your location and applicable law. They may include:

• Right of access – to request confirmation and a copy of personal data we hold about you.
• Right to rectification – to request correction of inaccurate or incomplete personal data.
• Right to erasure – to request deletion of personal data in certain circumstances.
• Right to restriction – to request restriction of processing in certain circumstances.
• Right to object – to object to processing based on our legitimate interests, and to opt out of direct marketing at any time.
• Right to data portability – to request a copy of certain personal data in a structured, commonly used, machine-readable format.

If you are in California, you may also have rights under the CCPA/CPRA, such as:

• the right to know what categories of personal information we collect and how we use them;
• the right to request access, correction or deletion of your personal information; and
• the right not to be discriminated against for exercising your privacy rights.

We do not sell personal information and do not use it for cross-context behavioural advertising.

You can exercise your rights by contacting us using the details in Section 12. We may need to verify your identity before responding. We will respond within the time required by applicable law.

11. Children's privacy

The Services are intended for adults and are not directed to children under 18. We do not knowingly collect personal data from anyone under 18.

If you believe we have collected personal data from a child, please contact us and we will take steps to delete that data and, where applicable, close the account.

12. Contact and complaints

If you have questions about this Privacy Policy or how we handle personal data, or if you wish to exercise any of your rights, you can contact us at:

• Email: privacy@vicewire.ai
• Postal address: ViceWire Pty Ltd, Suite 302, 13/15 Wentworth Ave, Sydney NSW 2000, Australia

If you are located in Australia and are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC).

If you are in the EU, UK or another jurisdiction, you may also have the right to complain to your local data protection authority.

13. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we do:

• we will update the "Last updated" date at the top of this page; and
• where changes are material, we will take reasonable steps to notify you (for example, via the website or by email if you have an account or subscription).

Your continued use of the Services after any changes come into effect will constitute your acceptance of the updated Privacy Policy.