Privacy Policy

This Privacy Policy describes how Pura Vida Connections LLC ("Puravida Edge," "we," "us," "our") collects, uses, shares, and protects personal information when you visit puravidaedge.com (the "Site") or use our products and services (collectively, the "Service").

This Policy applies to all users of the Service worldwide, with specific provisions for users in the European Economic Area (EEA), United Kingdom, and California, USA, as noted below.

By using the Service, you acknowledge that you have read this Privacy Policy.

1. Information We Collect

1.1 Information You Provide Directly

When you use the Service, we collect:

• Account information — email address and TradingView username (required to deliver invite-only strategy access)
• Payment information — handled by our payment processor Dodo Payments; we do not directly receive or store your full payment card details
• Communications — content of emails, support tickets, or messages you send us
• Refund requests — supporting information you provide when claiming a refund (e.g., TradingView strategy logs, configuration details)
• Marketing preferences — your consent or opt-out status for marketing communications

1.2 Information Collected Automatically

When you visit the Site, we may automatically collect:

• Technical data — IP address, browser type and version, operating system, time zone, device type, screen resolution
• Usage data — pages visited, time spent, referring URL, click patterns
• Cookies and similar technologies — see Section 8 for details

1.3 Information from Third Parties

We may receive information from:

• Dodo Payments — purchase confirmation, billing country, payment status (Dodo Payments is Merchant of Record and processes payments)
• TradingView — limited information related to invite-only strategy access management
• Analytics providers — aggregated usage data (where applicable; see Section 8)

1.4 Information We Do Not Collect

We do not knowingly collect:

• Government identification numbers (SSN, passport, national ID)
• Financial account numbers beyond what Dodo Payments processes for payment
• Health information
• Sensitive personal data (race, religion, sexual orientation, political opinions, etc.) unless you voluntarily provide such information in support communications
• Information from children under 18 (see Section 11)

2. How We Use Your Information

We process your personal information for the following purposes:

2.1 Service Delivery

• To grant TradingView invite-only access to the strategies you purchase
• To verify your eligibility for the Service (age, jurisdiction, identity matching purchase)
• To provide customer support
• To send transactional emails (purchase confirmation, refund updates, service notices)
• To deliver model updates and changelog notifications

2.2 Service Improvement

• To analyze usage patterns and improve the Site
• To debug technical issues and prevent abuse
• To monitor for fraudulent or suspicious activity

2.3 Legal and Compliance

• To comply with legal obligations (tax records, OFAC sanctions screening, etc.)
• To respond to legal process (subpoenas, court orders)
• To enforce our Terms of Service and protect our rights
• To investigate violations of our acceptable use policies

2.4 Marketing (With Your Consent Where Required)

• To send promotional emails about new strategies, pricing changes, or product updates
• To send newsletters if you have opted in

You can opt out of marketing emails at any time using the unsubscribe link in each email or by contacting privacy@puravidaedge.com. Transactional emails (e.g., purchase confirmations, security notices) cannot be opted out of as long as you have an active account.

3. Legal Bases for Processing (EEA/UK Users)

If you are in the European Economic Area or the United Kingdom, we process your personal information based on the following legal bases under the General Data Protection Regulation (GDPR) and UK GDPR:

| Processing Purpose | Legal Basis | |---|---| | Delivering the Service you purchased | Contract performance (Art. 6(1)(b) GDPR) | | Processing payments via Dodo Payments | Contract performance + legal obligation | | Sending transactional emails | Contract performance | | Customer support | Contract performance + legitimate interests | | Marketing communications | Consent (Art. 6(1)(a)) or legitimate interests with opt-out | | Fraud prevention, security, abuse detection | Legitimate interests (Art. 6(1)(f)) | | Compliance with tax and legal obligations | Legal obligation (Art. 6(1)(c)) | | Defense of legal claims | Legitimate interests |

You have the right to withdraw consent at any time where processing is based on consent. Withdrawal does not affect the lawfulness of prior processing.

4. How We Share Your Information

We do not sell your personal information. We share your information only as described below:

4.1 Service Providers / Sub-Processors

We share information with third parties that help us deliver the Service. These third parties act as sub-processors under contractual obligations to protect your information:

| Service Provider | Purpose | Data Shared | Location | |---|---|---|---| | Dodo Payments | Payment processing, Merchant of Record, tax handling, invoicing | Email, billing info, transaction data | USA | | TradingView | Strategy hosting and invite-only access | TradingView username | USA / global | | Kit | Transactional and marketing email delivery | Email, marketing preferences | [USA / EU] | | (not currently in use) | Site analytics | IP address, usage data (often anonymized/aggregated) | [USA / EU] | | Cloud hosting (Framer) | Website hosting | Site visit data | Global |

Each sub-processor's privacy practices are governed by their own privacy policies. We encourage you to review them.

4.2 Legal Requirements

We may disclose information if required by law, subpoena, court order, or other legal process, or if we believe in good faith that disclosure is necessary to:

• Comply with applicable law
• Enforce our Terms of Service
• Protect our rights, property, or safety, or that of our users or the public
• Detect, investigate, or prevent fraud or security issues

4.3 Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of substantially all our assets, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent Site notice of any such transfer.

4.4 With Your Consent

We may share information with other third parties when you give us explicit consent.

5. International Data Transfers

We are based in the United States, and our service providers may process data in the United States or other countries. If you are located outside the United States, your information will be transferred to, stored in, and processed in the United States.

For users in the EEA and UK, we rely on the following legal mechanisms for cross-border transfers:

• EU Standard Contractual Clauses (SCCs) with our sub-processors
• UK International Data Transfer Agreement (IDTA) or UK Addendum to the EU SCCs
• Other transfer mechanisms approved under applicable data protection law

By using the Service, you acknowledge that your personal information may be transferred internationally.

6. Data Retention

We retain personal information for as long as necessary to:

• Provide the Service to you
• Comply with our legal obligations (e.g., tax records typically retained for 7 years)
• Resolve disputes and enforce our agreements
• Defend against legal claims

Specifically:

| Data Category | Retention Period | |---|---| | Account information (email, TradingView username) | Duration of account + 3 years after termination | | Purchase and billing records | 7 years (tax compliance) | | Customer support communications | 3 years after last contact | | Marketing email subscriber lists | Until unsubscribe + 1 year | | Site usage analytics | 26 months (typical for analytics tools) or as configured by analytics provider | | Refund request documentation | 7 years (financial records) |

After applicable retention periods expire, we delete or anonymize the data.

7. Your Rights

Depending on your jurisdiction, you have certain rights regarding your personal information. We provide all users the rights below regardless of jurisdiction, where technically feasible:

7.1 Universal Rights

• Access — request a copy of the personal information we hold about you
• Correction — request correction of inaccurate or incomplete information
• Deletion — request deletion of your information (subject to legal retention obligations)
• Restriction — request that we limit how we use your information
• Portability — request a copy of your information in a structured, machine-readable format
• Objection — object to processing based on legitimate interests
• Withdraw consent — withdraw consent where processing is based on consent
• Complaint — file a complaint with a data protection authority

7.2 EEA/UK Users (GDPR / UK GDPR)

In addition to the universal rights, EEA and UK users may:

• File a complaint with their national supervisory authority (list available at edpb.europa.eu or ico.org.uk)
• Object to automated decision-making (we do not engage in automated decision-making with legal or significant effect)

7.3 California Users (CCPA / CPRA)

California residents have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

• Right to know — what categories of personal information we collect, the purposes of collection, the categories of sources, and the categories of third parties to whom we share information
• Right to delete — request deletion (subject to exceptions)
• Right to correct — request correction of inaccurate information
• Right to opt out of sale or sharing — we do not sell personal information; we share information only with service providers as described in Section 4
• Right to limit use of sensitive personal information — we do not collect sensitive personal information for purposes that would trigger this right
• Right to non-discrimination — we will not discriminate against you for exercising your privacy rights

7.4 Other US State Privacy Laws

Residents of Virginia, Colorado, Connecticut, Utah, Texas, and other states with comprehensive privacy laws have similar rights. We honor these rights consistent with applicable state law.

7.5 How to Exercise Your Rights

To exercise any right described above, contact us at privacy@puravidaedge.com with:

• Your name and email address as registered with us
• The specific right you wish to exercise
• Sufficient information for us to verify your identity (we may need to ask for additional verification)

We will respond within 30 days (or as required by applicable law). For complex requests, we may extend the response time by an additional 60 days with notice to you.

8. Cookies and Tracking Technologies

8.1 What We Use

We may use cookies and similar tracking technologies on the Site, including:

• Strictly necessary cookies — required for the Site to function (authentication, security, load balancing)
• Functional cookies — remember your preferences (language, region)
• Analytics cookies — measure usage (via (not currently in use), where applicable)
• Marketing cookies — limited use; if used, only with consent

8.2 Your Choices

You can control cookies through:

• Your browser settings (block, delete, or limit cookies)
• Our cookie banner (where presented for EEA/UK users)
• Browser plugins (e.g., Ghostery, Privacy Badger)
• Opt-out mechanisms provided by analytics or advertising networks

Disabling cookies may affect Site functionality.

8.3 Do Not Track

Some browsers send "Do Not Track" signals. We do not currently respond to such signals because there is no consistent industry standard. You can use the controls in Section 8.2 to manage tracking.

9. Data Security

We implement administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, and destruction. These include:

• Encryption in transit (TLS/HTTPS) for data transmitted between your device and our systems
• Encryption at rest for stored sensitive data where supported by our sub-processors
• Access controls and authentication for our team members
• Vendor diligence for sub-processors
• Regular review of security practices

However, no system is perfectly secure. We cannot guarantee absolute security of your information. If a data breach affects your personal information, we will notify you and applicable authorities as required by law.

10. Third-Party Links and Services

The Site may contain links to third-party websites, integrations with third-party platforms (TradingView, TradersPost, PineConnector, prop firms), and references to third-party tools. We are not responsible for the privacy practices of these third parties. Their privacy policies govern their handling of your information.

11. Children's Privacy

The Service is not directed at children under 18 years of age. We do not knowingly collect personal information from anyone under 18. If you believe a child has provided us with personal information, please contact us at privacy@puravidaedge.com and we will take steps to delete it.

12. Changes to This Policy

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

• We update the "Last Updated" date at the top of the document
• For material changes, we notify you via email or a prominent Site notice

Your continued use of the Service after changes take effect constitutes acceptance of the updated Policy.

13. Contact Us

Questions, requests, or complaints regarding this Privacy Policy or your personal information should be directed to:

Pura Vida Connections LLC 1209 Mountain Road PL NE STE N, Albuquerque, NM 87110, USA Email: privacy@puravidaedge.com Website: puravidaedge.com

If you are an EEA or UK resident and we are unable to resolve a concern, you have the right to file a complaint with your local data protection authority.