Privacy Policy

1. Who We Are

ARIA is an agentic research and investment assistant operated by ARIA PM Ltd, a company registered in England and Wales. We are the data controller responsible for your personal data.

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us at support@ariapm.ai.

2. What Data We Collect

We may collect and process the following categories of data:

• Account data: name, email address, password (stored in encrypted form), and account preferences
• Billing and payment data: billing name, address, payment card details (processed securely by our payment provider; we do not store full card numbers), and transaction history
• Portfolio and investment data: portfolio holdings, investment preferences, risk profiles, watchlists, and research queries you submit to the platform
• Technical data: IP address, browser type and version, device type, operating system, time zone setting
• Usage data: pages visited, features used, navigation paths, session duration, and interaction patterns
• Communications data: support tickets, feedback, and email correspondence
• Marketing preferences: your communication and marketing opt-in choices

3. How We Collect Your Data

We collect personal data through:

• Direct interactions: when you create an account, subscribe to our service, enter portfolio data, use our AI research tools, or contact us
• Automated technologies: when you interact with our website and platform, we automatically collect technical and usage data through cookies and similar technologies (see our Cookie Policy)
• Third-party sources: authentication providers (e.g. Google Sign-In), payment processors, and analytics services

4. Lawful Basis for Processing

We only process your personal data where we have a lawful basis under the UK GDPR. The bases we rely on include:

• Performance of a contract: to provide our platform, manage your account, process payments, and deliver the services you have subscribed to
• Legitimate interests: for platform analytics, improving our services, ensuring security, and fraud prevention, where our interests do not override your rights
• Consent: for marketing communications and non-essential cookies. You may withdraw consent at any time
• Legal obligation: to comply with tax, accounting, and regulatory requirements

5. How We Use Your Data

We use your personal data to:

• Provide and operate the ARIA platform, including AI-powered research and portfolio analysis
• Create and manage your account
• Process subscription payments and billing
• Generate personalised investment research and insights using artificial intelligence
• Respond to enquiries and provide customer support
• Send service-related notifications (e.g. subscription confirmations, feature updates)
• Send marketing communications (where you have opted in or we have a legitimate interest)
• Analyse platform usage and improve our services
• Detect and prevent fraud, abuse, and security incidents
• Comply with legal and regulatory obligations

6. AI and Automated Processing

Our platform uses artificial intelligence to analyse market data, generate investment research, and provide portfolio insights. This involves:

• Analysing your portfolio holdings and investment preferences to provide relevant research
• Processing your research queries using AI models to generate insights and analysis
• Using aggregated and anonymised usage data to improve our AI capabilities

We do not use automated decision-making that produces legal or similarly significant effects on you. All AI-generated content is provided as informational research and analysis, not as personalised financial advice. You retain full control over any investment decisions you make.

We do not use your personal data or portfolio data to train third-party AI models. We may use anonymised and aggregated data to improve our own AI capabilities, but such data cannot be used to identify you.

7. Who We Share Your Data With

We may share your personal data with the following categories of recipients:

• Service providers: cloud hosting, email, analytics, payment processing, and AI infrastructure providers who act on our behalf under data processing agreements
• Professional advisors: lawyers and accountants as needed
• Regulatory authorities: HMRC, the ICO, the FCA, or other bodies when required by law

We do not sell your personal data to any third party.

8. International Transfers

Some of our service providers are based outside the United Kingdom. Where we transfer personal data internationally, we ensure appropriate safeguards are in place, including:

• Transfers to countries with a UK adequacy decision in place
• UK International Data Transfer Agreements or the UK Addendum to EU Standard Contractual Clauses

You may request a copy of the safeguards we use by contacting us at support@ariapm.ai.

9. How Long We Keep Your Data

We retain personal data only for as long as necessary for the purposes for which it was collected:

• Account data: retained for the duration of your account and for up to 6 years after account closure (to comply with legal and tax obligations)
• Billing and transaction data: 7 years (as required by UK tax law)
• Platform usage data: up to 2 years for analytics purposes, then anonymised or deleted
• Marketing consent records: until consent is withdrawn, plus 2 years after unsubscription
• Support tickets: up to 3 years after resolution
• Security logs: up to 1 year

Where possible, we anonymise personal data that we no longer need to identify you. Anonymised data may be retained and used indefinitely for analytics and service improvement.

10. Your Rights

Under the UK GDPR, you have the following rights in relation to your personal data:

• Right of access: request a copy of the personal data we hold about you
• Right to rectification: request correction of inaccurate or incomplete data
• Right to erasure: request deletion of your data in certain circumstances
• Right to restrict processing: request that we limit how we use your data
• Right to data portability: receive your data in a structured, machine-readable format
• Right to object: object to processing based on legitimate interests or for direct marketing
• Right to withdraw consent: where we rely on consent, you may withdraw it at any time without affecting the lawfulness of prior processing
• Rights related to automated decision-making: not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects

To exercise any of these rights, please email us at support@ariapm.ai. We will respond within one month. This period may be extended by up to two further months for complex requests, in which case we will inform you of the extension.

11. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or alteration. These include:

• Encryption of data in transit (TLS/HTTPS) and at rest
• Access controls and authentication mechanisms
• Regular security assessments
• Incident response procedures

While we strive to protect your personal data, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security.

12. Children's Privacy

Our platform is not intended for individuals under 18 years of age. We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child, we will take steps to delete that information as soon as possible.

13. Cookies

Our website uses cookies and similar technologies. For full details on which cookies we use and how to manage them, please see our Cookie Policy.

14. Third-Party Links

Our platform may contain links to third-party websites or services. This Privacy Policy does not apply to those third-party services, which operate under their own privacy policies. We encourage you to review the privacy policies of any third-party services you use.

15. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated revision date. For material changes, we will notify you by email or through a prominent notice on our platform.

16. Complaints

If you are unhappy with how we handle your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

• Information Commissioner's Office
• Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
• Helpline: 0303 123 1113
• Website: ico.org.uk

We would appreciate the opportunity to address your concerns before you contact the ICO. Please reach out to us at support@ariapm.ai first.

17. Contact Us

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

• ARIA PM Ltd
• Email: support@ariapm.ai
• Website: ariapm.ai