| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Name, postal address, email address, telephone number, username, IP address, brokerage account identifiers, API tokens | YES |
| B. Personal Information (Cal. Civ. Code § 1798.80(e)) | Name, address, telephone number, financial account information | YES |
| C. Protected Classifications | Age (to verify 18+) | YES |
| D. Commercial Information | Trade history, transaction records, order submissions, order execution results, profit/loss information, subscription records | YES |
| E. Internet / Network Activity | Browsing history, search queries, usage details, interaction with website or service, cookies data, device information, browser type, operating system | YES |
| F. Geolocation Data | General location data | YES |
| G. Sensory Information | None | NO |
| H. Professional / Employment Information | None | NO |
| I. Non-Public Education Information | None | NO |
| J. Inferences | Preferences and behavior patterns related to service usage | YES |
We collect the following categories of sensitive personal information:
• Account credentials (username and password)
• Financial account information (processed through Stripe; we do NOT store full credit card numbers)
We collect personal information from the following sources:
• Directly from you when you register, use our service, or communicate with us
• Automatically through cookies, web beacons, and tracking technologies
• From third parties including:
- Brokerage firms (trade execution data)
- Payment processors (transaction confirmation)
- Service providers supporting our operations
3. PURPOSES FOR COLLECTING PERSONAL INFORMATION
We use personal information for the following business and commercial purposes:
Service Delivery:
• Providing and maintaining the Many Hats algorithmic trading service
• Processing account registration and authentication
• Executing trade orders through connected brokerage accounts
• Providing trading analytics and performance metrics
Business Operations:
• Processing payments and billing through Stripe
• Responding to customer support requests
• Sending account notifications and service updates
• Enforcing our Terms and Conditions of Service
• Detecting and preventing fraud and abuse
• Improving platform functionality and user experience
Communication:
• Responding to your inquiries
• Sending promotional communications (with your consent)
• Notifying you of service changes
Legal Compliance:
• Complying with legal obligations
• Protecting rights, property, and safety
• Responding to government or regulatory requests
We do NOT use your personal information to train AI systems or third-party data models.
4. DISCLOSURE OF PERSONAL INFORMATION
| Category | Third Parties |
|---|---|
| Identifiers | Service providers, payment processors (Stripe), brokerage firms, subsidiaries and affiliates |
| Commercial Information | Service providers and brokerage firms for trade execution |
| Internet / Network Activity | Service providers for analytics and hosting |
| Financial Information | Payment processors (Stripe – PCI DSS compliant) |
| Geolocation Data | Service providers |
Recipients of Personal Information:
• Service providers (contractors bound by confidentiality obligations)
• Payment processors (Stripe for billing)
• Brokerage firms (to execute your trade instructions)
• Subsidiaries and affiliates
• Professional advisors (legal, accounting)
• Business transferees (in event of merger, acquisition, or asset sale)
• Government entities (when legally required)
5. SALE AND SHARING OF PERSONAL INFORMATION
We do NOT sell your personal information.
We do NOT share your personal information for cross-context behavioral advertising.
We have not sold or shared personal information in the past 12 months and do not have actual knowledge that we sell or share personal information of consumers under 16 years of age.
6. RETENTION OF PERSONAL INFORMATION
We retain personal information for as long as necessary to:
• Provide you with the Many Hats service
• Maintain your account
• Comply with legal, tax, and regulatory obligations (typically 7 years for financial records)
• Resolve disputes and enforce our agreements
• As otherwise disclosed at the time of collection
When you close your account, we delete personal information unless retention is required by law or legitimate business purposes (such as fraud prevention).
7. YOUR CALIFORNIA PRIVACY RIGHTS
As a California resident, you have the following rights:
A. Right to Know
You may request that we disclose:
• Categories of personal information collected
• Categories of sources
• Business/commercial purposes for collection
• Categories of third parties with whom we share personal information
• Specific pieces of personal information collected about you
B. Right to Delete
You may request deletion of personal information we collected from you, subject to certain exceptions (e.g., completing transactions, legal compliance, fraud detection).
C. Right to Correct
You may request correction of inaccurate personal information we maintain about you.
D. Right to Limit Use of Sensitive Personal Information
We do not use or disclose sensitive personal information for purposes other than those permitted under CCPA (service delivery, security, legal compliance). Therefore, this right does not apply to our current practices.
E. Right to Opt-Out of Sale/Sharing
Since we do not sell or share personal information, this right does not currently apply. If our practices change, we will provide a "Do Not Sell or Share My Personal Information" link.
F. Right to Non-Discrimination
We will not discriminate against you for exercising your CCPA rights, including by:
• Denying goods or services
• Charging different prices or rates
• Providing a different level or quality of service
• Suggesting you will receive a different price or service level
8. HOW TO EXERCISE YOUR RIGHTS
To exercise your rights to know, delete, or correct your personal information:
Email: [email protected]
Mail: Many Hats, LLC
251 W. Central Ave. #138
Springboro, OH 45066
Online: Log into your account at app.nxtdeal.io and visit your account profile page
Verification Process
To protect your privacy, we will verify your identity before responding to your request. We may ask you to:
• Provide identifying information (name, email, account details)
• Confirm recent account activity
• Respond to verification emails
For requests to know specific pieces of information or delete personal information, we require a higher level of verification.
Authorized Agents
You may designate an authorized agent to submit requests on your behalf. The agent must:
• Provide written authorization signed by you, or
• Present a valid power of attorney under California Probate Code
We may still require you to verify your identity directly or confirm you provided the agent permission.
Response Timing
We will respond to verifiable requests within 45 days. If we need more time (up to 90 days total), we will notify you of the reason and extension period.
9. NO DISCRIMINATION FOR EXERCISING RIGHTS
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by law, we will not:
• Deny you access to the Many Hats service
• Charge you different prices or rates
California Civil Code Section § 1798.83 permits California residents to request information about disclosure of personal information to third parties for direct marketing purposes.
We do not share personal information with third parties for their direct marketing purposes.
If you have questions, contact us at [email protected].
We do not currently offer financial incentives or price differences related to the collection, retention, or sale of personal information.
12. CHANGES TO THIS NOTICE
Material changes will be communicated through:
• A notice on our website homepage
13. CONTACT INFORMATION
For questions about this CCPA Privacy Notice or our privacy practices:
Many Hats, LLC
251 W. Central Ave. #138
Springboro, OH 45066
Notice at Collection Summary
We collect identifiers, commercial information, internet activity, geolocation data, financial information (processed via Stripe), and account credentials to provide our algorithmic trading service, process payments, prevent fraud, and improve our platform. We do not sell your personal information. For more details, see the full CCPA Privacy Notice above.
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