1. Introduction
Terminal Up Inc., a Delaware corporation ("Terminal Up," "Company," "we," "us," or "our"), operates the website located at TerminalUp.com (the "Site") and related software products and services (collectively, the "Services"). This Privacy Policy describes how we collect, use, disclose, and protect your personal information when you access or use our Site and Services.
Terminal Up is a software technology company. We do not operate, facilitate, or provide any gambling, wagering, betting, or gaming services or products. We do not accept deposits, hold customer funds, process bets, or act as a bookmaker or exchange in any capacity.
By accessing or using our Site or Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree, please do not access or use our Site or Services.
2. Information We Collect
2.1 Information You Provide Directly
We collect information that you voluntarily provide to us, including:
- Contact Information: First and last name, email address, company or organization name, and any other information you include in contact form submissions or email correspondence.
- Inquiry Details: Information about your trading volume, position sizes, and specific questions or messages submitted through our contact forms, including the Contact page and ArbTaker inquiry form.
- Account Information: If you create an account or register for early access, we may collect your username, email address, and authentication credentials.
- Communications: Records and content of any correspondence between you and Terminal Up, including emails, support requests, and feedback.
2.2 Information Collected Automatically
When you access our Site, we may automatically collect:
- Device Information: Browser type and version, operating system, device type, screen resolution, and unique device identifiers.
- Log Data: IP address, access times, pages viewed, referring URL, clickstream data, and time spent on pages.
- Usage Data: Information about how you interact with our Site, including navigation paths, features used, and interaction patterns.
- Location Data: Approximate geographic location derived from your IP address.
2.3 Cookies and Tracking Technologies
We use cookies, web beacons, pixels, and similar tracking technologies to collect information about your browsing activity. These technologies help us analyze trends, administer the Site, track users' movements, and gather demographic information. You may control the use of cookies through your browser settings. Disabling cookies may limit your ability to use certain features of our Site.
Types of cookies we may use include:
- Essential Cookies: Required for the operation of our Site (e.g., session management, theme preferences).
- Analytics Cookies: Help us understand how visitors interact with our Site by collecting and reporting information anonymously.
- Functional Cookies: Enable enhanced functionality and personalization.
3. How We Use Your Information
We use the information we collect for the following purposes:
- Service Delivery: To provide, operate, maintain, and improve our software products and Services.
- Communication: To respond to your inquiries, send service-related notices, and communicate about products, features, and updates.
- Analytics: To analyze usage patterns, monitor the effectiveness of our Site, and improve user experience.
- Security: To detect, prevent, and address fraud, unauthorized access, and other illegal or harmful activities.
- Compliance: To comply with applicable laws, regulations, legal processes, or governmental requests.
- Business Operations: To facilitate internal operations including data analysis, audits, and developing new products or features.
- Marketing: With your consent where required, to send you information about products or services that may be of interest to you. You may opt out of marketing communications at any time.
4. Legal Bases for Processing (EEA/UK Users)
If you are located in the European Economic Area (EEA) or United Kingdom (UK), our legal bases for processing your personal data include:
- Consent: Where you have given us explicit consent to process your data for a specific purpose.
- Contractual Necessity: Where processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract.
- Legitimate Interests: Where processing is necessary for our legitimate business interests, provided those interests are not overridden by your rights and freedoms.
- Legal Obligation: Where processing is necessary to comply with a legal obligation.
5. Information Sharing and Disclosure
We do not sell, rent, or trade your personal information to third parties. We may share your information in the following circumstances:
- Service Providers: We may share information with third-party vendors, consultants, and service providers who perform services on our behalf (e.g., hosting, analytics, email delivery), subject to confidentiality obligations.
- Legal Requirements: We may disclose information if required by law, subpoena, court order, or governmental regulation, or when we believe disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
- Business Transfers: In connection with a merger, acquisition, reorganization, sale of assets, or bankruptcy, your information may be transferred as a business asset. We will notify you of any such change in ownership or control of your personal information.
- With Your Consent: We may share your information for any other purpose with your explicit consent.
- Aggregated/De-identified Data: We may share aggregated or de-identified information that cannot reasonably be used to identify you.
6. Data Security
We implement commercially reasonable administrative, technical, and physical security measures designed to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit (TLS/SSL), access controls, and regular security assessments.
However, no method of electronic transmission or storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. You acknowledge that you provide your personal information at your own risk.
7. Data Retention
We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the data, and applicable legal requirements.
When personal information is no longer required, we will securely delete or anonymize it. Contact form submissions and inquiries are retained for the duration of our business relationship and for a reasonable period thereafter for record-keeping purposes.
8. Your Rights and Choices
Depending on your location and applicable law, you may have the following rights:
- Access: Request a copy of the personal information we hold about you.
- Correction: Request correction of inaccurate or incomplete personal information.
- Deletion: Request deletion of your personal information, subject to certain exceptions.
- Portability: Request a copy of your data in a structured, commonly used, machine-readable format.
- Restriction: Request restriction of processing of your personal information in certain circumstances.
- Objection: Object to processing of your personal information based on legitimate interests.
- Withdraw Consent: Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of prior processing.
- Non-Discrimination: You will not receive discriminatory treatment for exercising your privacy rights.
To exercise any of these rights, please contact us at win@terminalup.com. We will respond to your request within 30 days or as required by applicable law.
9. California Privacy Rights (CCPA/CPRA)
If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide you with additional rights regarding your personal information, including the right to know what personal information is collected, the right to delete, the right to opt out of the sale or sharing of personal information, and the right to non-discrimination.
We do not sell or share your personal information as those terms are defined under the CCPA/CPRA. To submit a verifiable consumer request, please contact us at win@terminalup.com.
10. International Data Transfers
Terminal Up is based in the United States. If you are accessing our Site or Services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States or other countries where our service providers operate. These countries may have data protection laws that differ from those in your jurisdiction. By using our Site or Services, you consent to the transfer of your information to the United States and other jurisdictions as described in this Privacy Policy.
Where required by applicable law, we implement appropriate safeguards for international data transfers, such as Standard Contractual Clauses approved by the European Commission.
11. Third-Party Platforms and Links
Our software products may interface with third-party exchanges, sportsbooks, and prediction markets. Our Site may also contain links to third-party websites or services. This Privacy Policy does not apply to any third-party websites, platforms, or services. We are not responsible for the privacy practices, content, or security of any third-party platforms. We encourage you to review the privacy policies of any third-party services before providing your personal information to them.
13. Do Not Track Signals
Some web browsers transmit "Do Not Track" (DNT) signals. Because there is no industry standard for DNT compliance, our Site does not currently respond to DNT signals. We will continue to monitor developments regarding DNT browser technology and the implementation of a standard.
14. Changes to This Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes, we will notify you by updating the "Last Updated" date at the top of this page and, where required by applicable law, by providing additional notice (such as email notification or a prominent notice on our Site). Your continued use of the Site or Services after any changes constitutes your acceptance of the updated Privacy Policy.
12. Children's Privacy
Our Site and Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information promptly. If you believe we have collected information from a child under 18, please contact us at win@terminalup.com.
15. Contact Information
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at: