Privacy Policy

1. Data Controller

SiennaCirrus Ltd. (referred to as "SiennaCirrus," "we," "us," or "our") is the data controller responsible for the collection and processing of your personal data through the Sienna Trade platform.

Contact Information:
SiennaCirrus Ltd.
Email: privacy@sienna.trade
Address: Newtown House, 38 Newtown Road, Liphook, United Kingdom, GU30 7DX

2. Information We Collect

2.1 Information You Provide

• Account Information: Email address, password (stored securely as hashes), name, and profile settings
• Financial Data: Trading preferences, strategy settings, and backtest configurations
• Communication Data: Information you provide when contacting our support team
• Billing information when applicable (processed through secure third-party payment processors)

2.2 Automatically Collected Information

• Usage Data: Information about how you interact with our platform, including pages visited, features used, and time spent
• Device Information: IP address, browser type, operating system, and device identifiers
• Cookies and Similar Technologies: Information collected through cookies as detailed in our Cookie Policy
• Performance metrics of your strategies and technical information about your usage patterns

2.3 Market Data

• Historical and real-time market data accessed through our platform
• Analysis results generated through our tools

3. Legal Basis for Processing

We process your personal data based on the following legal grounds:

• Performance of Contract: Processing necessary to provide our services and fulfill our contractual obligations to you
• Legitimate Interests: Processing necessary for our legitimate business interests, such as improving our platform, ensuring security, and marketing our services
• Consent: Processing based on your explicit consent, which you can withdraw at any time
• Legal Obligations: Processing necessary to comply with applicable laws and regulations

4. How We Use Your Data

We use your information to:

• Provide and maintain our platform services
• Authenticate you and secure your account
• Improve and personalize your experience
• Develop new features and functionality
• Communicate with you about your account and our services
• Analyze usage patterns and optimize our platform
• Process transactions and manage your account
• Monitor platform performance
• Ensure compliance with our terms and applicable regulations

Our engineering team continually works to enhance platform performance, carefully balancing system resources to ensure your strategies execute efficiently.

5. Data Sharing and Third Parties

We do not sell your personal information or trading strategies to third parties. We may share data in the following limited circumstances:

• Service Providers: Third-party vendors who help us operate our platform, including hosting, analytics, and customer support providers
• Business Partners: Companies we partner with to offer integrated services
• Legal Authorities: When required by law, court order, or governmental authority
• Corporate Affiliates: In the event of a merger, acquisition, or business transfer

We ensure appropriate safeguards are in place when sharing your data with third parties.

6. Google Authentication

When you choose to sign in using Google, we receive and process certain information from your Google account:

• Basic Profile Information: Your name, email address, and profile picture
• Authentication Token: A secure identifier that allows us to verify your identity

How We Use Google Account Data

• To create or link your Sienna Trade account
• To authenticate you during sign-in
• To display your profile information within our platform

Data Sharing with Google

We do not share your Sienna Trade activity or data back to Google beyond what is necessary for authentication purposes. When you use Google authentication, Google's privacy policy applies to the data collected by Google. We recommend reviewing Google's Privacy Policy for more information.

Disconnecting Google Authentication

You can disconnect your Google account from Sienna Trade at any time through your account settings. Disconnecting will not delete your Sienna Trade account, but you will need to use another authentication method to access your account.

7. Data Retention

We retain your personal data for as long as necessary to provide our services and fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

After the applicable retention period expires, we will securely delete or anonymize your data.

8. Your Rights

Under the GDPR and other applicable data protection laws, you have certain rights regarding your personal data:

• Right to Access: Request a copy of the personal data we hold about you
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data
• Right to Restriction: Request restriction of processing your data
• Right to Data Portability: Receive your data in a structured, commonly used format
• Right to Object: Object to processing based on legitimate interests or for direct marketing
• Right to Withdraw Consent: Withdraw consent at any time for processing based on consent

To exercise your rights, please visit your account settings or contact us at privacy@sienna.trade. We will respond to your request within 30 days.

You also have the right to lodge a complaint with a supervisory authority if you believe your rights have been violated.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction.

Our security measures include:

• Encryption of data in transit and at rest
• Regular security assessments and penetration testing
• Access controls and authentication requirements
• Regular security training for our staff
• Continuous monitoring for suspicious activities

However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

10. Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will:

• Notify the relevant supervisory authority without undue delay and, where feasible, within 72 hours of becoming aware of the breach
• Notify you directly if the breach is likely to result in a high risk to your rights and freedoms
• Provide information on the nature of the breach, categories of data affected, potential consequences, and measures taken to address the breach

11. International Data Transfers

We may transfer your personal data to countries outside the European Economic Area (EEA). When we do, we ensure appropriate safeguards are in place, such as:

• Transferring to countries recognized by the European Commission as providing adequate protection
• Implementing Standard Contractual Clauses approved by the European Commission
• Using other legally approved transfer mechanisms

12. Children's Privacy

Our services are not intended for individuals under the age of 18. We do not knowingly collect personal data from children. If you become aware that a child has provided us with personal data, please contact us, and we will take steps to delete such information.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The updated version will be effective as of the date stated at the top of the policy.

We will notify you of any material changes by posting a notice on our website or sending you an email notification.

14. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact our Data Protection Officer at:

Email: privacy@sienna.trade
Address: Newtown House, 38 Newtown Road, Liphook, United Kingdom, GU30 7DX

Last Updated: April 4, 2025