1. Scope and controller
This Privacy Notice describes how BKI Technologies Inc. (“BKI Technologies”, “we”, “us” or “our”) may collect, use, store, disclose and otherwise process personal information when you access Portfolio Builder, Portfolio Genie, EPARCS or related websites and services (the “Platform”). BKI Technologies Inc. is the operator of the Platform and the controller of the personal information processed for its account, portfolio-analysis and customer-support services. For any privacy request, contact portfoliobuilder@blackkomodoinvestments.com. Where another related entity acts as a separate controller for a particular service, that entity will be identified in the relevant service notice.
2. Information we may collect
We may process account and identity information such as name or email address; authentication information such as securely stored password hashes; portfolio and financial information you voluntarily submit, including holdings, quantities, average prices, capital assumptions and investment preferences; risk-profiler responses; information extracted from portfolio images (but not the uploaded image files themselves); generated portfolio, simulation and analysis records; technical information such as browser, device, IP address, timestamps and diagnostic logs; and communications or support information you send to us. You should not submit brokerage passwords, bank credentials, private keys or other third-party authentication secrets.
2A. Portfolio-image processing
If you choose to upload a holdings screenshot, we use the image solely to read and extract the securities, share quantities and average purchase prices needed to prepare your analysis. The uploaded image file is not saved to your account or retained as an image by the Platform after processing. The uploaded file may pass through temporary request buffers while it is processed. Extracted text, corrected holdings and generated analysis may be kept in your analysis session or saved account so that you can review and resume your work. Please remove any unnecessary personal or account identifiers before uploading a screenshot.
3. Portfolio and inferred information
The Platform may derive information from your inputs, including estimated portfolio value, concentration, volatility, beta, sector exposure, risk classifications, preferences, proposed portfolio allocations and other analytical outputs. These are analytical inferences produced to operate the Platform and are not representations about your complete financial circumstances.
4. Purposes of processing
We may use information to create and authenticate accounts; provide and preserve separate Portfolio Builder and Portfolio Genie workspaces; perform requested portfolio construction, risk profiling, analytics, backtests and simulations; personalize the Platform based on submitted preferences; provide security and fraud prevention; diagnose errors; maintain records; improve functionality and performance; respond to support requests; and comply with applicable legal, regulatory or enforcement obligations.
5. Legal bases and consent
Where applicable data-protection law requires a legal basis, processing may be based on performance of a service requested by you, our legitimate interests in operating and securing the Platform, compliance with legal obligations, or consent where consent is required. Where processing relies on consent, you may withdraw that consent subject to applicable law, without affecting processing already lawfully undertaken.
6. Hosting, infrastructure and international transfers
The Platform uses cloud hosting and infrastructure, including Google Cloud services, as well as database, authentication, payment, market-data, news, security and monitoring providers where needed to deliver the services. Depending on the provider and your location, personal information may be processed outside your country of residence. Where required by applicable law, we use appropriate safeguards for international transfers. No country-specific data residency is promised unless expressly stated in a separate agreement.
7. Third-party data and services
The Platform may communicate with third-party services to obtain market prices, security information, news or other data. Those providers may receive technical requests necessary to provide their services and may maintain their own privacy terms. Links to external websites are provided for convenience and are not governed by this Notice.
8. Cookies, sessions and similar technologies
We use authentication and security cookies to maintain your account, workspaces and sign-in session. If you select “Stay signed in for 30 days,” your authenticated session cookie may persist for up to 30 days, subject to signing out, expiry or account deletion. Without that option, the browser session cookie normally ends when you close the browser. We will provide any notice and obtain any consent required by applicable law before using non-essential tracking technologies.
9. Security
We may use administrative, technical and organisational safeguards appropriate to the nature of the Platform, including access controls and protected authentication credentials. No internet transmission, database or cloud environment can be guaranteed to be completely secure. You are responsible for protecting your account credentials and for promptly notifying us if you believe your account has been compromised.
10. Retention
Personal information may be retained for as long as reasonably necessary to provide the Platform, preserve your requested workspaces, maintain security and audit records, resolve disputes and meet legal or regulatory obligations. Retention periods may vary by data category and applicable law. When you delete your account from Profile, your account record and saved portfolios are deleted from the primary account store and the recorded billing subscriptions are cancelled as part of that process. Certain transactional, legal, tax, fraud-prevention, security, backup and payment-provider records may remain for legally required or legitimate retention periods, after which they are deleted or anonymised as appropriate.
11. Your rights
Depending on your location and applicable law, you may have rights to request access to, correction of, deletion of, restriction of, portability of, or objection to certain processing of your personal information, and rights relating to consent or complaints to a competent data-protection authority. These rights may be subject to legal exceptions. To exercise your rights or raise a privacy concern, email portfoliobuilder@blackkomodoinvestments.com. You may also delete your account from Profile after signing in. We may need to verify your identity before acting on a request; any mandatory local legal rights and complaint mechanisms continue to apply.
12. Children
The Platform is not intended for children and should not be used by anyone who lacks legal capacity to agree to the applicable Terms. We do not knowingly seek to collect personal information from children through the Platform.
13. Informational financial technology
Portfolio holdings, risk-profiler responses and related financial information are processed to provide analytical functionality. Portfolio Builder, Portfolio Genie, EPARCS outputs, classifications, simulations, historical comparisons and market commentary are provided for informational and educational purposes only. Processing financial information does not make BKI Technologies a custodian of your assets and does not itself create an investment-management, advisory, brokerage, fiduciary, legal, accounting or tax relationship.
14. Changes to this Notice
We may update this Notice as the Platform, infrastructure, service providers or applicable requirements evolve. Material changes should be reflected by an updated effective date and, where required, additional notice.
Operator and contact
The Platform is operated by BKI Technologies Inc. and its related entities. Privacy, account deletion and legal enquiries: portfoliobuilder@blackkomodoinvestments.com. Applicable mandatory privacy and consumer rights are respected regardless of location.
