Privacy Policy

1. Introduction

Scrutar is a platform for reading and analyzing the filings of public companies ("the Service"). It is owned and operated by Tecemal Technologies Inc. ("Tecemal", "we", "us", "our"), a corporation incorporated in Canada, which is responsible for the personal information described in this policy. Company details are published at tecemal.com/company.

This Privacy Policy explains what information we collect when you use scrutar.com and the Scrutar application, why we collect it, who processes it, how long we keep it, and the choices you have.

2. Information We Collect

2.1 Information you provide

• Account information: your name and email address, together with any information you choose to add to your profile.
• Your research: watchlists, alert rules, saved screens and searches, matrices, investment memos, and the notes, theses, checklists and decisions you keep in your research journal. The journal is private to you and is never sent to an AI provider.
• Ask Scrutar conversations: the questions you ask and the answers you receive, stored against your account so you can revisit them (see section 4).
• Feedback and messages: feedback you submit in the application and messages you send through the contact form, including your name, email address and message.
• Email subscriptions on the public pages: if you ask to be emailed when a company files, we keep the email address you give us and the companies you chose. We send a confirmation email first, and every message carries an unsubscribe link.
• Billing information: if you subscribe to a paid plan, your payment details are collected and processed by Stripe, our payment processor. We store your subscription status and a Stripe customer reference, never your card number.

2.2 Information collected automatically

• Usage data: pages visited, features used, search queries, companies researched and filings viewed.
• Device and browser information: browser type, operating system and screen size.
• Log data: IP address, access times and referring pages, kept for security, rate limiting and troubleshooting.
• Sign-in location: when you sign in, we look up the approximate city and country of your IP address through a geolocation service and keep it with your sign-in history, so we can tell you when your account is used from somewhere new.

3. How We Use Your Information

We use the information we collect to:

• provide and improve the Service, including your watchlists, research journal, alerts and notifications;
• answer your requests, including questions to Ask Scrutar, semantic search, memos and analysis;
• send the alerts and filing emails you have asked for, and emails about your account, such as a sign-in from a new location, a receipt, a change to the Service or a change to our terms;
• send occasional product updates about new features, unless you turn them off in your account settings or with the unsubscribe link in any of them;
• respond to your feedback and support requests;
• understand how the Service is used, in aggregate, so we can improve it;
• detect and prevent fraud, abuse and security incidents, and enforce our terms.

Notices about your account, billing and our terms are always sent. Product updates are optional. We do not sell your personal information.

4. AI Processing

Scrutar uses third-party AI models, hosted by AI providers based in the United States, to read filings, extract data, summarize events, analyze risk and guidance, and power the Ask Scrutar conversational interface.

• When you use an AI feature, your question, the relevant filing content and the context needed to answer are sent to the AI provider for processing.
• We do not send your account information (name, email address, billing details) or your research journal to AI providers.
• Your Ask Scrutar questions and answers are stored against your account for 90 days so you can return to them. You can delete any conversation entry yourself at any time.
• We record aggregate usage figures (token counts, request volumes, model used) for monitoring and cost control. These figures do not contain the text of your questions.

5. Who Processes Your Information

We share information only with providers that help us run the Service, under agreements that require them to protect it, and in the other limited cases below.

• Hosting and email delivery: our servers, database and outbound email run on Amazon Web Services. Cloudflare serves the public pages and protects the Service at the network edge.
• Payments: Stripe.
• AI providers: as described in section 4.
• Sign-in location: a geolocation service that receives your IP address at sign-in.
• Spam protection: the contact form and the email signup forms on our public pages use Google reCAPTCHA, which receives browser and IP information to tell people from bots, under the Google Privacy Policy.
• Analytics: see section 10.
• Webhooks you configure: if you point notifications at a URL of your own, the content of those notifications is sent to that URL.
• Legal requirements: when required by law, a court order or a regulator, or to protect the rights, safety or property of Tecemal, our users or the public.
• Business transfers: in a merger, acquisition or sale of assets, your information may be transferred as part of that transaction, under this policy.

6. Where Your Information Is Stored

Tecemal is based in Canada and operates the Service from there. Our servers and the providers named above are located in the United States, so your information is stored and processed there, where privacy laws may differ from those of your own country. We take reasonable steps to make sure it receives comparable protection wherever it is processed.

7. Data Retention

• Account information and your research are kept for as long as your account is active.
• Ask Scrutar conversations are kept for 90 days, or until you delete them.
• Records of the alerts we sent you and of activity on your account are kept for 90 days; security logs for 30 days.
• Contact form and feedback submissions are kept for as long as needed to respond and to keep a record of the conversation.
• Public email subscriptions are kept until you unsubscribe.
• Analytics data is kept by the analytics providers under their own retention settings (section 10).

When you delete your account, your personal information and research are deleted promptly, except where we must keep a record by law, to resolve a dispute or to enforce our agreements. Copies in backups are removed as the backups expire.

8. Data Security

We protect your information with encryption in transit (TLS), encryption at rest for our database and storage, token-based access controls and regular security reviews. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

9. Your Rights and Choices

Under Canada's Personal Information Protection and Electronic Documents Act, and equivalent laws where you live, you can:

• Access the personal information we hold about you.
• Correct information that is inaccurate or incomplete.
• Delete your account and its information from the Settings page in the application.
• Receive a copy of your information in a portable format, on request by email.
• Object to, or ask us to restrict, certain processing.
• Withdraw consent for analytics (section 10) or unsubscribe from any email using the link in it.

To exercise a right that is not available in the application, email support@scrutar.com. We answer within 30 days. If you are not satisfied with our response, you can complain to the Office of the Privacy Commissioner of Canada or to the data protection authority where you live.

10. Cookies, Local Storage and Analytics

Scrutar uses your browser's local storage to keep you signed in and to remember preferences such as your theme, and a cookie to remember your analytics choice for a year. This data stays on your device and is not shared with anyone.

Google Analytics runs only if you accept it in the banner shown on your first visit. If you decline, it is not loaded. If you accept, it records the pages you visit, how long you stay, your general location and the actions you take on our public pages, such as opening the pricing table or starting a signup. IP addresses are anonymised, and the data is processed by Google under its Privacy Policy.

Cloudflare Web Analytics runs separately from the choice above, on both the public pages and the application. Cloudflare adds a small script to our pages that reports which page was viewed, the site the visit came from and how quickly the page loaded. It sets no cookie, stores nothing on your device, gives you no identifier and does not follow you across other sites. Because it recognizes no one, it runs whether or not you accept the analytics above, and it is covered by the Cloudflare Privacy Policy.

Cloudflare also delivers and protects the Service, and in doing so records the technical details of each request (your IP address, browser type, the page you requested and the time) to serve the site and block abuse. This is necessary to run the Service.

Scrutar's own page counts record which pages are opened on the public pages and inside the application. This sets no cookie and does not identify public visitors. We use it only to understand which companies and features are popular and where Scrutar needs to improve.

You can change your analytics choice at any time. On this site, use Cookie preferences in the footer. In the application, use Cookie preferences on the Settings page. A choice made in either place applies to both.

11. Children's Privacy

The Service is not intended for anyone under 18. We do not knowingly collect personal information from children, and we delete it promptly if we learn we have.

12. Changes to This Policy

We may update this policy. When we do, we post the new version here and change the "Last updated" date, and we tell you in the application or by email if the change is material. Your continued use of the Service after a change takes effect means you accept the updated policy.

13. Contact

Questions about this policy or about your information go to support@scrutar.com, or through the feedback feature in the application. Legal notices to Tecemal Technologies Inc. go to hello@tecemal.com.