Privacy Policy
1. Who we are
This Privacy Policy explains how GENIUS AI PTE. LTD. ("Ticks", "we", "us"), a company registered in Singapore (UEN 202543916W, registered office 150 Cecil Street, #15-01, Singapore 069543), collects, uses, shares and protects your personal data when you use the Ticks mobile application and related services (the "App").
Privacy contact / Data Protection Officer: privacy@ticksai.app — GENIUS AI PTE. LTD., 150 Cecil Street, #15-01, Singapore 069543.
An EU representative under Article 27 GDPR will be appointed prior to any launch in the European Union.
2. What Ticks is (and is not)
Ticks is an information and education application. It displays market situations produced by our proprietary engine, with their structure and the reasoning behind it, for illustrative and educational purposes only.
Ticks does not connect to any broker or exchange, does not execute orders, does not manage portfolios, and does not provide personalised investment advice. As a result, we do not process brokerage-account data, order data, or real financial balances.
Your use of the App is also governed by our separate Terms of Use and Risk Disclosure.
3. The personal data we collect
a) Data you provide
Account data: email address and password (passwords are stored hashed, never in clear text); or, if you use Sign in with Apple or Google Sign-In, the authentication identifier and email supplied by that provider.
If you sign in with Apple and choose to hide your email address, we receive a relay address ending in @privaterelay.appleid.com. We never receive your real address in that case, and messages we send to the relay are forwarded to you by Apple. You can stop that forwarding at any time in your Apple Account settings.
Figures you enter: if you use position sizing, you enter a net liquidity figure yourself. We store it so the calculation persists across your devices. It is a number you type; we never verify it against any external source.
Preference data: the situations you follow, selected markets, sort and display preferences, notification settings.
Support data: anything you send us when contacting support.
b) Data collected automatically
Device and technical data: device model, operating system and version, language, app version, IP address, and app/device identifiers.
Usage and diagnostic data: screens viewed, features used, session data, crash and error logs.
Push notification token: to inform you as a situation you follow develops (only if you enable notifications).
c) Purchase data (iOS)
Subscriptions are sold and processed by Apple through the App Store. We never receive your payment card details, your Apple Account identifier or your billing address.
What we receive is a transaction receipt, which we verify with Apple's servers and record against your account. From it we know which product was purchased, when the subscription started, when it renews and whether it is active. Apple also notifies our servers when a subscription is renewed, cancelled, refunded or fails to renew, so that your access level stays correct.
d) Referral data (Android)
Where access is obtained through one of our partner brokers, only a referral or click identifier is shared with that broker so the sign-up can be attributed to Ticks.
We do not share your App activity or your usage data with the broker, and we do not receive your brokerage account data from them.
e) What we do not collect
We do not collect your brokerage credentials, your account balances, your trading history or your positions. We do not collect precise location data. We do not use advertising identifiers and we show no advertising. We do not knowingly collect special-category or sensitive data.
4. How we use your data, and our legal bases
| Purpose | Legal basis (GDPR / equivalent) |
|---|---|
| Create and manage your account | Performance of a contract |
| Display content and keep track of what you follow | Performance of a contract |
| Deliver notifications you opted into | Consent |
| Manage and verify subscriptions | Performance of a contract |
| Attribute a referral to a partner broker | Legitimate interests |
| Answer your support messages | Performance of a contract / legitimate interests |
| Keep the service secure and prevent abuse | Legitimate interests |
| Diagnose crashes and improve reliability | Legitimate interests |
| Send service and legal updates | Legitimate interests / legal obligation |
| Send marketing emails, if any | Consent (withdrawable at any time) |
| Meet accounting and tax obligations | Legal obligation |
Under the PDPA, we process this data with your consent or as permitted by that Act. Where we rely on consent, you may withdraw it at any time without affecting prior processing.
5. Third-party services and SDKs
We use trusted providers who process data on our behalf. These are mirrored in our Apple App Privacy labels and Google Play Data Safety section, kept consistent with this policy:
- Analytics: Firebase Analytics (Google)
- Crash reporting: Firebase Crashlytics (Google)
- Push notifications: Firebase Cloud Messaging (Google), Apple Push Notification service
- Subscription processing and receipt verification: Apple
- Authentication: Apple (Sign in with Apple), Google (Google Sign-In)
- Transactional email: MailerLite
- Referral attribution: the partner broker's own referral link with a click identifier — no third-party attribution SDK
- Cloud hosting: Amazon Web Services (AWS) — United States
6. When we share your data
We do not sell your personal data, and we do not share it for anyone else's marketing. We disclose it only:
- to the service providers listed above, under contract, to run the App;
- to Apple, as part of subscription processing;
- to a partner broker, limited to the referral identifier described in Section 3(d);
- where required by law, regulation or valid legal process;
- in a merger, acquisition or asset sale (with notice where required);
- with your consent.
7. International data transfers
We operate from Singapore and our cloud hosting is in the United States, so your data is transferred internationally.
From the EEA, UK or Switzerland: we rely on the European Commission's Standard Contractual Clauses (with the UK Addendum and Swiss addendum as applicable) and, where our US providers are certified, the EU-US Data Privacy Framework. You may request a copy of the safeguards at privacy@ticksai.app.
From Asia-Pacific markets: where local law requires, we provide notice of and/or obtain consent for the overseas transfer of your data before or at collection.
Under the PDPA, we require every recipient to provide a standard of protection comparable to that Act.
8. How long we keep your data
Account data: for the life of your account, then deleted within 30 days of account deletion.
Preferences and followed situations: for the life of your account.
Purchase and transaction records: five years after the end of the subscription, as required by Singapore accounting and tax law. This obligation survives account deletion — the record is retained but no longer linked to an active profile.
Analytics and crash data: up to 14 months.
Support correspondence: up to three years after the exchange closes.
9. Deleting your account
You can delete your account from within the App, under Settings → Account → Delete account. No request to us is required.
Deletion is permanent. Your account, your preferences and the situations you follow are removed within 30 days, apart from the transaction records described in Section 8.
Deleting your Ticks account does not cancel an active Apple subscription. You must cancel it separately in your Apple Account settings, otherwise it continues to renew and to be charged.
10. Your rights
Depending on your jurisdiction (see Section 14), you may have the right to access, correct, delete, object to or restrict processing, withdraw consent, request portability, and lodge a complaint with your data protection authority.
To exercise a right, email privacy@ticksai.app. We respond within the timeframe required by law, and in any event within 30 days.
11. Security
We apply technical and organisational measures appropriate to the risk, including encryption in transit and at rest, hashed passwords, and restricted, logged access to production systems.
No system is perfectly secure. Where a breach is likely to result in significant harm, we will notify you and the competent authority within the timeframes required by the PDPA and the GDPR.
12. Age
Ticks is not intended for children. We do not knowingly collect data from anyone below the age at which they can enter into a binding contract in their jurisdiction. If you believe a minor has created an account, contact us and we will delete it.
13. Cookies and similar technologies
The App uses SDKs and device identifiers for analytics and notifications as described above. Our websites use cookies that are strictly necessary to operate and, where you consent, measurement cookies. You can refuse or withdraw consent at any time from the cookie banner or your browser settings.
14. Region-specific supplements
Where a supplement conflicts with the main policy, the supplement controls for residents of that jurisdiction.
14.1 EEA and UK — GDPR / UK GDPR. Controller and legal bases: Sections 1 and 4. Rights: access, rectification, erasure, restriction, objection, portability, withdrawal of consent. You may complain to your national authority (CNIL in France, the Garante in Italy, the AP in the Netherlands, the DPC in Ireland, and others). Transfers: Section 7. An EU representative under Article 27 will be appointed before EU launch.
14.2 Switzerland — nFADP. Equivalent rights; complaints to the FDPIC; transfers under the Swiss addendum or recognised mechanisms.
14.3 Singapore — PDPA. As a Singapore entity we handle data under the PDPA, on consent or a lawful exception. You may withdraw consent and request access or correction via our DPO (Section 1). Complaints: PDPC.
14.4 Australia — Privacy Act / APPs. Australian users may access and correct data and complain to the OAIC; cross-border disclosures follow APP 8.
14.5 Japan — APPI. We follow APPI rules on purpose specification, third-party provision, and cross-border transfer notice and consent.
14.6 South Korea — PIPA. We obtain consent for collection, third-party provision and overseas transfer, and describe retention and destruction.
14.7 Other Asia-Pacific. Hong Kong (PDPO), Taiwan (PDPA), Malaysia (PDPA), Thailand (PDPA): processed on a consent basis with access and correction rights.
14.8 California, USA — CCPA/CPRA. California residents may request to know, delete and correct personal information and to opt out of "sale" or "sharing" (we do not sell). We honour Global Privacy Control signals and do not discriminate for exercising rights. The categories of personal information we collect are described in Section 3.
15. Changes to this policy
We may update this policy. We will post the new version with an updated date and, for material changes, give in-App or email notice.
16. Contact
privacy@ticksai.app — GENIUS AI PTE. LTD., 150 Cecil Street, #15-01, Singapore 069543.
Ticks is a product of GENIUS AI PTE. LTD., Singapore (UEN 202543916W). Ticks provides educational information only and does not constitute financial, investment or trading advice. Trading financial markets involves a significant risk of loss.