Tier1 Alpha, Inc. (the “Company” or “we” or “us”) is committed to protecting the confidentiality and security of information we collect on all users and visitors to (the “Website”) and (the “App”). The purpose of this Privacy Notice is to tell users how we handle, protect, and limit the use of the Information that we collect in order to provide you with and administer the services you purchase from the Company.

Information we collect

The types of information we collect depend on your interactions with us and may include the following information (hereinafter “Personal Information”):

  • Identification data
    Full name, title, gender, sex, marital status, date of birth, passport number, driving license number, national identification number, signature
  • Contact data
    Personal address, telephone number, email address
  • Payment details
    Your bank account information, credit card number, and other information used to process payments
  • Subscription and usage information:
    Information about the products or services you subscribe to and how you use them, including preferences, browsing history, and help information
  • Financial and Portfolio data
    Information about your finances and investment portfolio
  • Professional Information data
    Employment history, position/job title, work address; telephone number; email address; educational attainment
  • Profile data
    Username and password for our online services that you have access to; services or tools requested; marketing communications responded to; survey responses
  • Technical data
    Your use of and interaction with our online services; your IP address; browser type and version; browser plug in types and versions; operating system
  • Protected Classification Characteristics under California or Federal Law
    Age (40 years or older), national origin, citizenship, marital status, sex (some information in this category may overlap with other categories)


How We Collect Personal Information

We collect Personal Information in relation to you in a number of ways, including:

  • When you use, purchase, or subscribe to our services (including but not limited to all ranges, indicators, models, and calendars);
  • Throughout the course of our relationship with you, including when you change your details, ask us for support, interact with us, or provide additional Personal Information or if the nature of our relationship to you changes; and,
  • from visits or logins to our Website or App.


We may also collect information about you from third parties, including:

  • Your employer, organization, or other third party that arranges access to our services for you;
  • Our partners and other service providers that work with us to provide you with our products or services; or,
  • Other publicly available sources.


The Company may also create or derive Personal Information (such as creating records of your interactions with us) subject to applicable laws.

If you do not provide the Personal Information requested, you may not be able to subscribe to our services.

How we use your Personal Information

We use your Personal Information in order to:

  • To provide you with the services to which you subscribe;
  • To personalize the content you receive, to create and administer your subscription, and to send you important product update information;
  • To screen certain ineligible persons, such as minors, from purchasing a subscription;
  • To respond to your inquiries and send you communications regarding your investments as well marketing materials;
  • To interact with governmental or regulatory authorities or other bodies with the requisite jurisdiction;
  • To obtain your feedback about the Website or App;
  • Enforce our contracts, terms, and conditions, or otherwise exercise our legal rights; defend ourselves from claims; and comply with laws and regulations that apply to us or third parties with whom we work;
  • To perform, anti-money laundering, anti-terrorism, sanction screening, fraud, and other due diligence checks as necessary; and
  • To detect or prevent fraud and/or other criminal activity and to protect our affiliates, employees, and assets.


We will not share nonpublic Personal Information with third parties without your consent, except for the specific purposes described above or as required by law.

Storage of Personal Information

We protect Personal Information by maintaining physical, electronic, and procedural safeguards that comply with applicable laws and federal regulations. We train our employees in the proper handling of Personal Information. They may access your Personal Information only when there is an appropriate reason to do so, such as to service and administer your business with the Company.

Our Company will keep your Personal Information while you either (1) are an active subscriber to one or more of the services that the Company provides and for a period of 3 years after you after you cease to be a subscriber or (2) for 3 years if you are not a subscriber. Once this time period has expired, we will delete your data by manually removing your information from our databases and third party services.


The Company would like to send you information about additional services in which you may want to subscribe.

You have the right at any time to stop the Company from contacting you for marketing purposes.

If you no longer wish to be contacted for marketing purposes, please click here. ☐

Your Personal Information Protection Rights

Every user that is a resident of the European Union (“EU”) or is a resident of the State of California is entitled to the following:

  • The right to access: You have the right to request from the Company copies of your Personal Information. We may charge you a small fee for this service.
  • The right to rectification: You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
  • The right to erasure/deletion: You have the right to request that we erase or delete your Personal Information, under certain conditions.
  • The right to restrict processing: You have the right to request that we restrict the processing of your Personal Information, under certain conditions.
  • The right to object to processing: You have the right to object to our processing of your Personal Information, under certain conditions.
  • The right to Personal Information portability: You have the right to request that we transfer the Personal Information that we have collected to another organization, or directly to you, under certain conditions.
  • The right to Opt-Out of Selling Personal Information: The Company neither currently sells nor plans to sell your Personal Information. However, if we change this policy, we will inform our users. In such instance, we will provide users with the right to opt-out -meaning the right to tell us to stop selling your Personal Information.


You or your authorized representative may exercise the rights above if you submit a request to the contact listed below.

  • All requests must be submitted by a resident of the EU or of the State of California or such resident’s authorized representative or legal guardian.
    • If you are making a request through an agent acting on your behalf, please provide proof of written authorization to do so via a power of attorney or other document. The Company may ask you and your agent to verify your identities.
  • Please provide The Company with sufficient information to allow us to reasonably verify that you are the person from whom we collected Personal Information. You may be asked to verify your residency and identity.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to your request.
  • The Company cannot and has no obligation to respond to request or to provide you with Personal Information if we cannot verify your identity or authority to make such a request. We only use such information to verify the requestor’s identity or a representative’s authority to make the request.


We will respond to requests in a timely manner.

  • We are obligated to respond to requests from EU residencies within one month of receipt.
  • We are obligated to confirm receipt of a request from a California resident within 10 days of receipt. Then, we have 45 days to respond to your request. If necessary, the CCPA allows us an additional 45 days to respond. We will inform you of our need for an extension if necessary.


Privacy Policies of Other Websites

The Company’s Website or App may contain links to other websites. This Privacy Notice applies only to our Website and App, so if you click on a link to another website, you should read its privacy policy.

Changes to Our Privacy Notice

The Company regularly reviews its Privacy Notice and places any updates on this web page. This Privacy Notice was last updated on August 23, 2021.

Contact Information: If you have any questions about this Privacy Notice, please contact us at [email protected].