GDPR Notice

Data Controller and Contact

Market Pulse 11 (mp11.org) is the data controller for the processing of personal data described in this notice.

Owner and Controller: 20383a 1a3e31454d3c

Registered Address: 1000 E 41st St, Austin, TX 78751, United States of America

Contact Email: [email protected]

If you have questions about this notice or wish to exercise your rights, please contact us using the details above.

Scope and Applicability

This notice describes how Market Pulse 11 processes personal data of individuals located in the European Economic Area (EEA), the United Kingdom, and Switzerland in accordance with the General Data Protection Regulation (GDPR) and applicable data protection laws. It supplements other privacy disclosures we may provide in the United States of America.

Categories of Personal Data We Process

Data You Provide

• Account and profile details (e.g., name or alias, email address, password or authentication credentials)
• Watchlists, screeners, saved preferences, alerts, and other user-generated settings
• Communications and support requests
• Newsletter and marketing subscription choices

Data Collected Automatically

• Technical identifiers and device data (e.g., IP address, browser type, operating system, device identifiers)
• Usage and interaction data (e.g., pages viewed, features used, time stamps, referring/exit pages)
• Cookies, web beacons, local storage, and similar technologies used for functionality, analytics, personalization, and advertising

Data from Third Parties

• Market data, news, blockchain/on-chain metrics, and related content from data providers
• Analytics and measurement information from service providers
• Basic campaign metrics from email delivery providers

We do not intentionally collect special categories of personal data (e.g., health, biometric, or sensitive data) for the services described.

Purposes of Processing and Legal Bases

• Provide and operate our services, including account features, watchlists, screeners, alerts, charts, and educational content (Legal basis: performance of a contract, Art. 6(1)(b); legitimate interests, Art. 6(1)(f))
• Measure and improve the performance, stability, and security of our site and services (Legal basis: legitimate interests, Art. 6(1)(f))
• Personalize content and remember user preferences (Legal basis: consent for non-essential cookies, Art. 6(1)(a); legitimate interests for necessary functionality, Art. 6(1)(f))
• Send administrative messages and respond to inquiries (Legal basis: performance of a contract, Art. 6(1)(b); legitimate interests, Art. 6(1)(f))
• Send marketing communications where permitted and with appropriate consent (Legal basis: consent, Art. 6(1)(a); or legitimate interests, Art. 6(1)(f), where allowed)
• Protect against fraud, abuse, and security risks; enforce terms; comply with legal obligations (Legal basis: legitimate interests, Art. 6(1)(f); legal obligations, Art. 6(1)(c))

Cookies, Tracking Technologies, and Analytics

We use first- and third-party cookies and similar technologies to enable core functionality, remember preferences, perform analytics, and support marketing. Where required, we obtain your consent for non-essential cookies and provide controls to modify your choices.

• Strictly necessary: enable core site functions, authentication, and security
• Preferences: store user settings such as watchlists and interface choices
• Analytics: measure usage and performance to improve the service
• Marketing: support newsletters and audience measurement

You can manage cookie preferences via browser settings and any on-site controls we provide. Some features may not function without certain cookies. We do not currently respond to browser Do Not Track signals.

Recipients and International Transfers

Categories of Recipients

• Hosting, cloud, and infrastructure providers
• Analytics and measurement service providers
• Email and communication delivery vendors
• Professional advisers (e.g., legal and accounting), and authorities where required by law

International Transfers and Safeguards

Your personal data may be transferred to, stored in, or accessed from the United States of America and other jurisdictions that may not provide the same level of data protection as the EEA/UK. Where required, we implement appropriate safeguards for such transfers, including Standard Contractual Clauses or other lawful transfer mechanisms, and apply additional technical and organizational measures as appropriate.

Retention of Personal Data

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, regulatory, accounting, or reporting requirements, and to resolve disputes.

• Account and profile data: retained for the life of the account and a reasonable period thereafter (typically up to 24 months) unless a longer period is required by law or for the establishment, exercise, or defense of legal claims
• Usage logs and analytics: typically retained for up to 12
  7 months in aggregated or pseudonymized form
• Marketing records: retained until you withdraw consent or object, plus a limited period to maintain suppression lists
• Cookies: retained according to their expiration settings; non-essential cookies typically expire within 13 months

Your Rights under the GDPR

• Access: obtain confirmation whether we process your personal data and receive a copy
• Rectification: request correction of inaccurate or incomplete data
• Erasure: request deletion in circumstances set out by law (e.g., when data are no longer necessary)
• Restriction: request limited processing while we assess a challenge to accuracy or our processing
• Portability: receive data you provided in a structured, commonly used, machine-readable format and transmit it to another controller where technically feasible
• Objection: object to processing based on legitimate interests or for direct marketing
• Consent withdrawal: withdraw consent at any time where processing is based on consent
• Complaint: lodge a complaint with a competent supervisory authority

How to Exercise Your Rights

To exercise your rights, contact us at [email protected]. We may request information to verify your identity. We will respond without undue delay and within one month of receipt, extendable as permitted by law where requests are complex or numerous. Exercising your rights is generally free of charge, but we may charge a reasonable fee or refuse a request where allowed by law (e.g., manifestly unfounded or excessive requests).

Automated Decision-Making and Profiling

We do not engage in decision-making that produces legal or similarly significant effects based solely on automated processing. We may use limited profiling for personalization (e.g., content preferences and feature recommendations) consistent with the purposes described above and subject to your rights.

Data Security

We implement appropriate technical and organizational measures to protect personal data, including encryption in transit, access controls, least-privilege principles, monitoring, logical segregation, and regular review of security practices. No method of transmission or storage is entirely secure; we strive to maintain measures commensurate with the risk.

Breach Notification

Where required by law, we will notify the competent supervisory authority of a personal data breach without undue delay and, where feasible, within 72 hours after becoming aware of it. When the breach is likely to result in a high risk to your rights and freedoms, we will also notify you without undue delay, consistent with legal requirements and our incident response procedures.

Lawful Basis for Marketing Communications and Opt-Out

We send marketing communications to you only where permitted by applicable law and with your consent where required. You can opt out at any time by using unsubscribe mechanisms in our messages or by contacting [email protected]. We will continue to send transactional or service-related messages as necessary.

Childrens Data

Our services are not directed to children under the age of 16, and we do not knowingly collect personal data from them. If you believe a child has provided us personal data, please contact us so we can take appropriate action.

Relationship to United States Law

This GDPR notice is designed to be consistent with applicable laws of the United States of America and to supplement other disclosures we may provide under U.S. state or federal law. Where both apply, we will honor the stronger protection available to you.

Data Protection Queries and Requests

You may direct all privacy-related questions and rights requests to: 20383a 1a3e31454d3c, 1000 E 41st St, Austin, TX 78751, United States of America; Email: [email protected].

Changes to This Notice

We may update this GDPR notice from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. Material changes will be indicated by updating the effective date or otherwise drawing attention to the update as appropriate. Your continued use of our services after an update signifies your acknowledgment of the revised notice.