Privacy Policy

Ask PilotThis Subscription Services Agreement (hereinafter referred to as "the Agreement") is made and entered into, effective as of the date of your acceptance, by and between Peachy Portfolios LLC, DBA Asymmetric Edge (meaning Peachy Portfolios LLC is doing business as Asymmetric Edge), a company incorporated in Lakewood, Colorado, United States (hereinafter referred to as "the Company"), and its subscribers (hereinafter referred to as "the Subscribers"). This Agreement sets forth the terms and conditions governing the provision of subscription-based newsletters and related services, ensuring compliance with applicable laws and fostering transparency in operations.
Definitions"Peachy Portfolios LLC, DBA Asymmetric Edge" refers to the Company providing subscription-based newsletters and related services, incorporated in Lakewood, Colorado, United States."Subscribers" refers to individuals or entities who have entered into a subscription agreement with the Company to receive paid newsletters or other related services."Newsletters" refers to the monthly updates provided by the Company, detailing model investment portfolio allocations and other relevant financial insights."Subscription Services" refers to the paid services offered by the Company, including newsletters, account management, and marketing communications."Stripe" refers to the third-party payment processor used by the Company to securely collect and process payment information."Mailchimp" refers to the email marketing platform used by the Company to distribute newsletters and marketing updates to Subscribers."Personal Data" refers to any information collected from Subscribers, including but not limited to first and last name, email address, physical address, and payment details."Consent" refers to the explicit agreement provided by Subscribers to receive marketing communications or newsletters, as obtained during the opt-in process."Applicable Laws" refers to all relevant federal and Colorado state regulations governing privacy, subscription-based services, and data protection."User Rights" refers to the rights granted to Subscribers under applicable laws, including the right to access, correct, delete personal data, and revoke consent for marketing communications.Overview and PurposePurpose of the Privacy PolicyThis Privacy Policy explains how Asymmetric Edge collects, uses, and protects your personal information. It is designed to ensure transparency in our data practices, comply with applicable Colorado state and U.S. federal privacy regulations, and build trust with our valued customers.Data Collection and UsageWe collect personal information such as your name, email address, and payment details to provide our subscription-based investment newsletters, manage your account, and send occasional marketing updates. This information helps us deliver relevant and timely investment insights tailored to your interests.Geographical ScopeOur services are intended exclusively for customers located within the United States. This Privacy Policy applies to the processing of personal information of U.S.-based users only.Compliance with RegulationsAsymmetric Edge adheres to all applicable Colorado state laws and U.S. federal privacy and subscription-based service regulations to ensure the secure and lawful handling of your personal information.Secure Payment ProcessingWe use Stripe to securely process subscriptions and payment information, ensuring compliance with industry-leading encryption and data protection standards.Legal Basis for ProcessingContractual Necessity1.1. We process your first name, last name, email address, physical address (collected via Stripe), and payment information (processed by Stripe) because it is necessary to perform our contract with you.1.2. This processing is essential for:a. Setting up and managing your subscription account.b. Processing subscription payments and renewals.c. Providing access to paid newsletter content.d. Sending transactional emails related to account status, payment confirmations, and service updates.Consent for Marketing and Newsletters2.1. We will only send you marketing emails and our free newsletter if you have given us your explicit consent to do so.2.2. Consent is obtained through an affirmative opt-in process, such as a checkbox on our website or a confirmation email.2.3. You have the right to withdraw your consent at any time by:a. Clicking the "unsubscribe" link in any email.b. Contacting us directly through the provided contact information.Compliance with Colorado Privacy Act (CPA)3.1. We ensure that all consent obtained aligns with the CPA definition, which requires a clear, affirmative act signifying your freely given, specific, informed, and unambiguous agreement to process your personal data.3.2. We collect and process only the personal data that is adequate, relevant, and limited to what is necessary for the specified purposes of contractual necessity and consent.3.3. This privacy policy provides transparency about the purposes for which personal data is processed and the legal bases for that processing.Payment Processing by Stripe4.1. Payment processing is handled by Stripe, which operates under its own privacy policy and legal basis for processing.4.2. Asymmetric Edge has limited access to your payment information, primarily for managing your subscription and reconciling payments.4.3. For more details on Stripe’s data processing practices, please refer to Stripe’s privacy policy.User RightsRight to Access1.1 Users have the right to request confirmation as to whether Asymmetric Edge processes their personal information. If processing occurs, users may access a copy of their data.1.2 Access requests must be submitted via the designated privacy contact email provided by Asymmetric Edge. Users must include their full name and the email address associated with their subscription for verification purposes.1.3 Asymmetric Edge will respond to access requests within 30 days of receipt, providing the information electronically via a secure download link.1.4 A reasonable fee may be charged for excessive or repetitive requests, as permitted by applicable law.Right to Correction (Rectification)2.1 Users have the right to request correction of inaccurate or incomplete personal information held by Asymmetric Edge.2.2 Correction requests must be submitted via the designated privacy contact email, specifying the data to be corrected and the proposed changes.2.3 Asymmetric Edge may verify the accuracy of the corrected information before updating its records.2.4 For payment information, corrections must be made directly through Stripe’s customer portal. For newsletter subscriptions, corrections may be made through Mailchimp’s profile management links.Right to Deletion (Erasure)3.1 Users have the right to request deletion of their personal information, subject to the following exceptions:a. Information necessary to fulfill active subscription obligations.b. Information required for legal compliance, such as tax records.c. Information necessary for the establishment, exercise, or defense of legal claims.3.2 Deletion requests must be submitted via the designated privacy contact email, including verification details.3.3 Asymmetric Edge will securely delete the data upon verification, except where exceptions apply.3.4 Deleting payment information may require coordination with Stripe, and subscription cancellation is necessary for account deletion.3.5 Unsubscribing from newsletters will prevent future communications, but permanent profile deletion must follow Mailchimp’s procedures.Right to Revoke Consent (for Marketing Communications)4.1 Users may withdraw their consent to receive marketing communications at any time.4.2 Consent revocation can be executed via the “unsubscribe” link in marketing emails or by contacting Asymmetric Edge directly.4.3 Users will be promptly removed from marketing lists upon revocation of consent.4.4 Revoking consent for marketing communications does not affect the receipt of essential transactional emails related to subscriptions.General Information5.1 Asymmetric Edge will not discriminate against users who exercise their privacy rights.5.2 Users may designate an authorized agent to make privacy-related requests on their behalf by providing appropriate documentation.5.3 Privacy-related inquiries and requests can be directed to Asymmetric Edge via the designated contact method provided in the privacy policy.Data RetentionPurpose of Data RetentionAsymmetric Edge retains personal data to provide subscription services, manage user accounts, comply with legal obligations, resolve disputes, and enforce agreements.Retention Periods by Data Categorya. Subscription and Account Data (Name, Email, Address):Subscription and account data, including name, email address, and address collected via Stripe, will be retained for the duration of an active subscription and for three (3) years following subscription termination. This retention period facilitates subscription renewals, inactive account management, and resolution of customer service inquiries.b. Payment Information (Processed by Stripe):Payment information is collected and processed by Stripe and is subject to Stripe's data retention policies. Peachy Portfolios LLC does not directly store payment information. Users are encouraged to refer to Stripe's privacy policy for details on their data retention practices.c. Marketing Communications Data (Email Addresses):Email addresses collected for marketing communications and newsletter subscriptions will be retained until the user unsubscribes or actively revokes consent. Upon unsubscription, the email address will be removed from active marketing lists, but a record of the opt-out request will be maintained to ensure compliance with marketing preferences.d. Website Usage Data (If Applicable):If Peachy Portfolios LLC implements cookies or tracking technologies on its website in the future, data collected through these means will be retained for twelve (12) months for analytical purposes.Legal and Regulatory ComplianceNotwithstanding the above retention periods, personal data may be retained for longer durations if required to comply with legal obligations, such as tax or accounting requirements, resolve disputes, or enforce agreements, in accordance with applicable U.S. and Colorado laws.Data Deletion or AnonymizationWhen personal data is no longer required for the purposes outlined in this Privacy Policy, it will be securely deleted or anonymized in accordance with industry best practices and applicable regulations.User Rights and RequestsUsers have the right to request deletion of their personal data, subject to Asymmetric Edge's ability to comply with legal and contractual obligations. Upon receiving a deletion request, the data will be securely deleted or anonymized as soon as reasonably possible, unless retention is required for legal or regulatory purposes.Security MeasuresData Encryption1.1. All sensitive personal information is protected using industry-standard encryption protocols to ensure its security both in transit and at rest.1.2. Encryption in Transit: Data transmitted between users' devices and Peachy Portfolios LLC's servers, including information submitted through website forms and during newsletter delivery, is encrypted using Transport Layer Security (TLS) or equivalent protocols.1.3. Encryption at Rest: Personal data stored on servers, including databases and backups, is encrypted using AES-256 or a comparable encryption standard.1.4. Key Management: Encryption keys are securely managed and stored to prevent unauthorized access, following best practices for key management.Access Control2.1. Access to personal information is restricted to authorized personnel only, based on the principle of least privilege.2.2. Role-Based Access: Employees are granted access solely to the data and systems necessary to perform their specific job functions.2.3. Authentication and Authorization: Strong authentication methods, including multi-factor authentication (MFA), are implemented for employees accessing systems containing personal information.2.4. Access Monitoring: Access to personal information is regularly monitored and audited to detect and prevent unauthorized access.Vendor Security3.1. Peachy Portfolios LLC engages third-party service providers, including Stripe and Mailchimp, to process personal information securely.3.2. Stripe Security: Payment information is collected and processed by Stripe, which complies with Payment Card Industry Data Security Standard (PCI DSS) Level 1. Peachy Portfolios LLC does not directly store or process credit card information.3.3. Mailchimp Security: Mailchimp employs robust security measures, including data encryption and access controls, to protect email addresses and newsletter content.3.4. Vendor Agreements: Peachy Portfolios LLC ensures that agreements with third-party vendors require them to maintain adequate security measures to protect personal information.Incident Response4.1. Asymmetric Edge has established procedures to respond promptly to security incidents, including data breaches or unauthorized access attempts.4.2. Breach Detection and Notification: Security incidents are detected and investigated using intrusion detection systems and security information and event management (SIEM) tools. Users will be notified promptly in the event of a data breach compromising their personal information, as required by applicable laws, including Colorado data breach notification laws.4.3. Remediation Measures: Steps to contain and remediate security incidents include isolating affected systems, patching vulnerabilities, and recovering data.Regular Security Assessments5.1. Asymmetric Edge conducts regular security assessments and vulnerability scans to identify and address potential security weaknesses.5.2. Vulnerability Scanning: Automated vulnerability scanning tools are used to identify potential security flaws in the website, servers, and applications.5.3. Penetration Testing: Periodic penetration testing is conducted by qualified security professionals to simulate real-world attacks and evaluate the effectiveness of security measures.5.4. Security Updates: Software and systems are regularly updated with the latest security patches to protect against known vulnerabilities.Use of Cookies and Tracking TechnologiesTypes of Cookies and Tracking Technologies Used1.1. First-Party Cookies: Peachy Portfolios LLC may use first-party cookies on its website to facilitate core functionality, such as session management, remembering user preferences, and maintaining login states.1.2. Third-Party Cookies: Third-party cookies may be set by services integrated into Peachy Portfolios LLC’s operations, including:(a) Stripe: Cookies used for payment processing, fraud prevention, and transaction security. Users are encouraged to review Stripe’s privacy policy for further details.(b) Mailchimp: Cookies used to track newsletter engagement, such as open rates and click-through rates, to improve content delivery. Users should refer to Mailchimp’s privacy policy for more information.1.3. Session Cookies: Temporary cookies that expire when the user closes their browser, used to track activity during a single browsing session.1.4. Persistent Cookies: Cookies that remain on the user’s device for a longer duration to remember preferences or login details for future visits.Purposes of Use2.1. Website Functionality: Cookies may be used to ensure the website operates correctly, including remembering user preferences an