1. Introduction

Nothing Happens LLC (“Company,” “we,” “us,” or “our”) is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our AI-powered financial services, visit our website, or interact with our platform.

This Privacy Policy applies to all services provided by Nothing Happens LLC, including but not limited to our algorithmic trading systems, investment management services, and related AI-powered financial tools.

2. Information We Collect

Personal Information

We collect personal information that you voluntarily provide to us, including:

• Identity Information: Full name, date of birth, Social Security number, government-issued ID
• Contact Information: Email address, phone number, mailing address
• Financial Information: Bank account details, investment accounts, financial statements, income information
• Employment Information: Employer details, job title, work address
• Investment Profile: Risk tolerance, investment objectives, trading experience

Automatically Collected Information

When you use our services, we automatically collect:

• Device Information: IP address, browser type, operating system, device identifiers
• Usage Information: Pages visited, time spent on platform, click patterns, feature usage
• Log Information: Server logs, error reports, performance metrics
• Location Information: General geographic location based on IP address

Financial and Trading Data

Through our AI systems, we collect and process:

• Trading history and portfolio performance
• Market data and investment preferences
• Risk management settings and alerts
• Communication logs with our AI agents

3. How We Use Your Information

We use your personal information for the following purposes:

Service Provision

• Provide AI-powered investment management and trading services
• Execute trades and manage your investment portfolio
• Generate personalized investment recommendations
• Process transactions and maintain account records

Legal and Regulatory Compliance

• Comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) requirements
• Meet SEC, CFTC, and other regulatory reporting obligations
• Conduct background checks and identity verification
• Maintain required financial records and audit trails

Communication and Support

• Send account statements, trade confirmations, and regulatory notices
• Provide customer support and respond to inquiries
• Send important updates about our services
• Deliver educational content and market insights

Platform Improvement

• Enhance our AI algorithms and trading strategies
• Improve platform security and performance
• Conduct research and data analysis
• Develop new features and services

4. AI Systems and Data Processing

AI Agent Data Usage

Our specialized AI agents process your data as follows:

Algorithmic Decision-Making

Our AI systems make automated decisions regarding:

• Trade execution within your predefined parameters
• Portfolio rebalancing and risk management
• Market opportunity identification
• Compliance monitoring and alert generation

Human Oversight: All AI decisions are subject to human review and override. You have the right to request human intervention in any automated decision-making process.

5. Information Sharing and Disclosure

We may share your personal information in the following circumstances:

Service Providers

We share information with trusted third-party service providers who assist us in:

• Payment processing and banking services
• Identity verification and background checks
• Data hosting and cloud storage
• Customer support and communication
• Legal and compliance services

Regulatory Authorities

We disclose information to regulatory bodies as required by law, including:

• Securities and Exchange Commission (SEC)
• Commodity Futures Trading Commission (CFTC)
• Financial Crimes Enforcement Network (FinCEN)
• State securities regulators

Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity, subject to the same privacy protections.

Legal Requirements

We may disclose your information when required by law, court order, or to:

• Comply with legal processes or investigations
• Protect our rights, property, or safety
• Prevent fraud or illegal activities
• Respond to government requests

6. Data Security and Protection

Security Measures

We implement comprehensive security measures to protect your information:

• Encryption: All data is encrypted in transit and at rest using AES-256 encryption
• Access Controls: Multi-factor authentication and role-based access controls
• Network Security: Firewalls, intrusion detection systems, and secure networks
• Regular Audits: Third-party security audits and penetration testing
• Employee Training: Regular security awareness training for all staff

Data Breach Response

In the unlikely event of a data breach, we will:

• Notify affected users within 72 hours
• Report to relevant regulatory authorities
• Conduct a thorough investigation
• Implement additional security measures as needed
• Provide credit monitoring services if appropriate

7. Data Retention and Storage

Retention Periods

We retain your personal information for the following periods:

• Account Information: For the duration of your relationship with us plus 7 years
• Trading Records: As required by regulatory guidelines (typically 5-7 years)
• Communication Logs: 3 years from the date of communication
• Marketing Data: Until you unsubscribe or withdraw consent

Data Storage

Your data is stored:

• In secure, SOC 2 Type II certified data centers
• With automatic backup and disaster recovery systems
• Using geographic redundancy across multiple locations
• Under strict access controls and monitoring

8. Your Privacy Rights

You have the following rights regarding your personal information:

Access and Portability

• Request access to your personal information
• Obtain a copy of your data in a portable format
• Review how your information is being used

Correction and Updates

• Correct inaccurate or incomplete information
• Update your contact details and preferences
• Modify your investment profile and risk settings

Deletion and Restriction

• Request deletion of your personal information (subject to regulatory requirements)
• Restrict certain uses of your information
• Object to specific data processing activities

Note: Some information cannot be deleted due to regulatory requirements for maintaining financial records.

9. Cookies and Tracking Technologies

Types of Cookies We Use

• Essential Cookies: Required for platform functionality and security
• Performance Cookies: Help us improve our services and user experience
• Functional Cookies: Remember your preferences and settings
• Analytics Cookies: Provide insights into platform usage and performance

Managing Cookies

You can control cookies through your browser settings. However, disabling certain cookies may limit your ability to use some features of our platform.

10. International Data Transfers

We may transfer your personal information to countries outside your jurisdiction for processing and storage. When we do so, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs)
• Adequacy decisions by relevant authorities
• Other legally recognized transfer mechanisms

11. Children’s Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If we become aware that we have collected information from a child under 18, we will take steps to delete such information promptly.

12. California Privacy Rights (CCPA)

If you are a California resident, you have additional privacy rights under the California Consumer Privacy Act:

Right to Know

• Categories of personal information we collect
• Sources of personal information
• Business purposes for collecting information
• Third parties with whom we share information

Right to Delete

Request deletion of your personal information, subject to certain exceptions for regulatory compliance.

Right to Opt-Out

We do not sell personal information to third parties. If our practices change, we will provide an opt-out mechanism.

Non-Discrimination

We will not discriminate against you for exercising your privacy rights under the CCPA.

13. European Privacy Rights (GDPR)

If you are in the European Economic Area (EEA), you have rights under the General Data Protection Regulation:

Legal Basis for Processing

• Contract Performance: Processing necessary to provide our services
• Legal Obligation: Compliance with financial regulations
• Legitimate Interest: Improving our services and preventing fraud
• Consent: Marketing communications (where required)

GDPR Rights

• Right to be informed
• Right of access
• Right to rectification
• Right to erasure
• Right to restrict processing
• Right to data portability
• Right to object
• Rights related to automated decision-making

To exercise these rights, please contact our Data Protection Officer using the information provided below.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will:

• Update the “Last Updated” date at the top of this policy
• Notify you via email or platform notification for material changes
• Provide a summary of significant changes
• Give you the opportunity to review the updated policy

Your continued use of our services after changes are made constitutes acceptance of the updated Privacy Policy.

15. Contact Information