Privacy Policy

Welcome to Ortex Technologies Limited’s privacy notice.

We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our websites, use our mobile application, or access our API and data services (regardless of where you access them from), and tell you about your privacy rights and how the law protects you.

This notice applies to your use of:

• our websites at ortex.com, ortex.news and ortex.app, and any subdomains of those domains;
• our mobile application (“ORTEX App”) distributed via the Apple App Store and Google Play Store;
• our application programming interfaces and data feed services; and
• any related services, features, content or applications offered from time to time by Ortex Technologies Limited (together, the “Services”).

US residents, including California residents, should also see section 11 below for privacy rights specific to your state.

1. Important information and who we are

Purpose of this privacy notice

This privacy notice (together with our terms of use and any other documents referred to in it) aims to give you information on how we collect and process your personal data through your use of the Services, including any data you may provide through our websites (ortex.com, ortex.news, ortex.app and their subdomains), our mobile application, or our API and data services, when you register to use our Services, subscribe to our products, search for information, configure alerts or watchlists, use our API, sign up to receive any information, request a call back or demo, purchase a product or service, request to go on our mailing list, receive any newsletter or take part in any competition.

The Services are not intended for children and we do not knowingly collect data relating to anyone under the age of 18. Our Services are financial-markets information tools intended for adult users only.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements any previous privacy notices and is not intended to override them. We reserve the right to make changes to our privacy notice and if we do the change will be posted on our websites and, where appropriate, notified through the ORTEX App, so you are advised to check periodically for updates.

Controller

Ortex Technologies Limited is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our”) in this privacy notice. For the purposes of the California Consumer Privacy Act and other US state privacy laws, we act as a “business” with respect to personal information we process about users of the Services.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

The Data Privacy Manager

Ortex Technologies Limited

The Old School House West Street,

Southwick, Fareham,

England, PO17 6EA

United Kingdom

Email: privacy@ortex.com

You have the right at any time to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This notice has been prepared in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, and, where applicable, the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act (together, the “CCPA”) and other applicable US state privacy laws. It was last updated in April 2026. Historic versions of our privacy notice can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us by notifying the Data Privacy Manager or by updating your account details within the Services.

Third-party links and integrations

The Services may include links to third-party websites, plug-ins, applications and integrated services (for example, single sign-on providers, payment processors, app-store platforms, brokerage connections and social media platforms). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third parties and are not responsible for their privacy statements. When you leave our Services or engage with a third-party integration, we encourage you to read the privacy notice of every website, application or service you use.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, and title.
• Contact Data includes billing address, email address and telephone numbers.
• Financial Data includes payment card details and bank account details, which are collected and processed by our third-party payment providers (such as Stripe) on our behalf; we do not store full payment card numbers on our systems.
• Transaction Data includes details about payments to and from you, subscription and add-on purchases, and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and approximate location, browser plug-in types and versions, operating system and platform, mobile device identifiers (including advertising identifiers such as Apple IDFA and Google Advertising ID, where permitted), device model, operating system version, mobile network information, push notification tokens, crash logs, API request logs, and other technology on the devices you use to access the Services.
• Profile Data includes your username and password, purchases or orders made by you, watchlists, saved searches, alert configurations, API usage patterns, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our websites, mobile application, API and Services, including the full Uniform Resource Locators (URL) clickstream to, through and from our sites; screens viewed and features used within the ORTEX App; API endpoints called and request volumes; products and tickers viewed and searched for; page or screen response time; download or loading errors; session length; and frequency of use.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, your push notification and in-app messaging preferences, and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not intentionally collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic or biometric data), and we do not collect information about criminal convictions and offences. Where we are required to perform know-your-customer or anti-money-laundering checks in respect of institutional clients, we may process limited identity-verification information on the lawful basis set out in section 4.

Under the CCPA, certain categories of personal information are defined as “sensitive personal information” (for example, account log-in credentials combined with a password). We use any such information we hold solely for the purposes set out in this notice and do not use it for purposes of inferring characteristics about you.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms on our websites or within the ORTEX App, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services directly or via our websites, mobile application or API;
• create an account on our websites, within the ORTEX App, or for API access;
• download, install, register for or use the ORTEX App;
• subscribe to our service, add-on products or publications;
• request information, a demo or marketing to be sent to you;
• enter a competition, promotion or survey;
• give us feedback.

Automated technologies or interactions. As you interact with the Services, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, API access logs, mobile software development kits (SDKs) and other similar technologies. In the ORTEX App we may also collect device-level information such as crash reports, diagnostic data and performance metrics. Please see our Cookie Policy and, where applicable, the in-app privacy disclosures, for further details.

App stores and mobile platform providers. When you download or install the ORTEX App, we may receive limited information from Apple (App Store) or Google (Google Play) about your installation, in-app purchases (where applicable) and certain device characteristics. Your use of each app store is also subject to that platform’s own terms and privacy policy.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services, including payment processors such as Stripe, based in the United Kingdom, the European Economic Area, the United States and other jurisdictions.
• Identity and Contact Data from publicly available sources such as Companies House, the Electoral Register, and equivalent public registers in other jurisdictions.
• Service providers acting as processors who provide cloud hosting, design services, analytics, IT and system administration services, including providers such as Amazon Web Services and Google.
• Professional advisers acting as processors including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom or elsewhere who require reporting of processing activities in certain circumstances.
• Analytics, advertising and attribution partners (such as Google Analytics and Google Ads) who provide information about how users discover and interact with the Services.
• For users accessing the Services through an institutional or enterprise subscription, we may receive Identity, Contact and Profile Data from the institution that has subscribed on your behalf.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email, push notification or text message, and in relation to certain cookies and similar technologies where consent is required. You have the right to withdraw consent at any time by contacting the Data Privacy Manager, by adjusting your preferences within the Services, or by following the opt-out instructions in the relevant communication.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact the Data Privacy Manager if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

The lawful basis for using your personal data

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

We strive to provide you with choices regarding certain personal data uses, particularly around any marketing and advertising.

Profiling and automated processing

Our Services include analytical tools and metrics generated from market and behavioural data, including short interest metrics, Short Score, ORTEX Alpha Trading Signals, Convergence Reports and AI-generated market intelligence content. Where these tools apply algorithmic logic to data about securities, markets or your own usage patterns, this may involve profiling of your Profile and Usage Data for the purpose of personalising content, tailoring alerts and recommending features. These outputs are informational only and do not produce legal or similarly significant effects on you; no solely automated decisions are made about you within the meaning of Article 22 of the UK GDPR. You can object to this processing by contacting the Data Privacy Manager.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us, purchased goods or services from us, registered for the ORTEX App or a promotion and, in each case, you have not opted out of receiving that marketing.

Push notifications

If you install the ORTEX App, we may send you push notifications (for example, price alerts, news updates or service messages). You can disable push notifications at any time through your device settings or by adjusting your preferences within the ORTEX App.

Third-party marketing

We will not share your personal data with any third party marketing company without your express consent.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into our websites or the ORTEX App and adjusting your marketing preferences, by following the opt-out links on any marketing message sent to you, by disabling push notifications in your device settings, or by contacting the Data Privacy Manager.

Cookies and similar technologies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our websites may become inaccessible or not function properly. Within the ORTEX App, you may be able to limit certain tracking by adjusting your device-level privacy settings (for example, “Allow Apps to Request to Track” on iOS or “Delete advertising ID” on Android). Please see our Cookie Policy for further information.

5. Institutional and enterprise users

Where you access the Services under a subscription taken out by your employer or another organisation (an “Institutional Client”), that Institutional Client is the contracting party with us, and we process your personal data as part of providing the Services to it. In that context:

• Your employer or the Institutional Client may receive usage reports, seat allocation information, and aggregated or individual usage metrics relating to your use of the Services, in accordance with the contract between us and the Institutional Client.
• You should refer to your Institutional Client’s own privacy notice and internal policies for information about how it uses personal data relating to your use of the Services within your employment or professional context.
• Requests to exercise rights over personal data processed on behalf of an Institutional Client should generally be directed to that Institutional Client in the first instance, and we will cooperate with the Institutional Client in responding to such requests as required by applicable law.

6. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table above:

External Third Parties

Third parties detailed in section 3 above, including cloud hosting, payment, analytics, advertising, customer support and communications providers.

Apple Inc. and Google LLC (and their affiliates) in connection with your download, installation, in-app purchases and use of the ORTEX App, subject to their own terms and privacy policies.

Where applicable, your employer or Institutional Client, as described in section 5.

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

Regulators, law enforcement, courts and other authorities where we are required to do so by law or where disclosure is necessary to protect our rights, property or safety, or that of our users or others.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

A list of our current sub-processors is available on request from the Data Privacy Manager.

7. International transfers

Some of our external third parties, including our cloud hosting, payment processing, analytics and communications providers, are based outside the United Kingdom and European Economic Area (EEA) (including in the United States), so their processing of your personal data will involve a transfer of data outside the UK and/or EEA.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK government (and, where applicable, the European Commission).
• Where we use certain service providers, we may use specific contracts approved for use in the UK (including the UK International Data Transfer Agreement or the International Data Transfer Addendum to the EU Standard Contractual Clauses) which give personal data the same protection it has in the UK.
• Where appropriate, we may rely on additional safeguards and conduct transfer risk assessments to ensure your data is adequately protected.

Please contact the Data Privacy Manager if you would like further information on the specific mechanism used by us when transferring your personal data outside the UK.

8. Data Security

We have put in place appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. These measures include encryption in transit and at rest, access controls, multi-factor authentication for administrative access, logging and monitoring, regular vulnerability and security testing, and regular review of our security practices. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. It will then be securely and permanently destroyed or anonymised.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

As an indicative guide:

• Account and subscription data is retained for the duration of your account plus six years after closure, for tax and accounting purposes.
• Transaction and payment records are retained for six years in accordance with UK tax law, and longer where required by US federal or state law.
• Technical logs and API access logs are generally retained for up to 13 months for security and debugging purposes.
• Marketing preferences and opt-out records are retained for as long as we send marketing to you, plus an additional period to evidence compliance.
• Support communications are typically retained for up to three years after closure of the relevant support request.

Further detail on retention periods is available in our retention policy, which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see section 10 below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

10. Your legal rights (UK and EEA)

Under certain circumstances, you have rights under UK and EEA data protection laws. These are as follows:

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

If you make a data subject access request:

Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

11. Privacy rights for US residents

This section applies to residents of US states with applicable consumer privacy laws, including California (CCPA/CPRA), Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPSA), Oregon (OCPA) and other states that have enacted comparable laws. In this section, references to “personal information” have the meaning given by the applicable state law.

Categories of personal information we collect, use and disclose

In the 12 months preceding the date of this notice, we have collected personal information in the categories set out in section 2 above, which correspond to the following CCPA categories: identifiers; customer records information; commercial information; internet or other electronic network activity information; geolocation data (approximate); and inferences drawn from any of the above. We use and disclose these categories of personal information for the purposes described in section 4 above.

Sources, purposes and recipients

The sources from which we collect personal information are described in section 3. The business and commercial purposes for which we use personal information are described in section 4. The categories of third parties with whom we disclose personal information are described in section 6.

Sale or sharing of personal information

We do not “sell” personal information for money. However, our use of certain advertising and analytics cookies and similar technologies on our websites may be considered “sharing” for cross-context behavioural advertising, or a “sale”, under some US state privacy laws. You can opt out of this activity at any time by:

• using the cookie preferences tool on our websites;
• enabling a Global Privacy Control (GPC) signal in your browser, which we will treat as a valid opt-out request for the browser on the device that sends it; or
• contacting us at privacy@ortex.com.

We do not knowingly sell or share the personal information of consumers under the age of 16.

Sensitive personal information

We do not use or disclose sensitive personal information for purposes that would require us to offer a right to limit its use and disclosure under the CCPA.

Your rights as a US resident

Depending on your state of residence, you may have the following rights:

• Right to know / access: to request that we disclose the categories and specific pieces of personal information we have collected, used, disclosed and (where applicable) sold or shared about you.
• Right to delete: to request that we delete personal information we have collected from you, subject to certain exceptions.
• Right to correct: to request correction of inaccurate personal information.
• Right to opt out of the sale or sharing of personal information and of targeted advertising, as described above.
• Right to limit the use or disclosure of sensitive personal information (California).
• Right to data portability: to receive a copy of your personal information in a portable format.
• Right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects (certain states).
• Right to non-discrimination: we will not discriminate against you for exercising any of these rights.

To exercise any of these rights, please contact us at privacy@ortex.com or use the privacy request form on our websites. We will verify your identity by asking you to confirm personal information that matches the information we already hold. If you use an authorised agent to submit a request, we may require written permission and verification of your identity as permitted by applicable law.

We will respond to a verifiable consumer request within 45 days of receipt (extendable by a further 45 days where reasonably necessary and with notice to you).

Right to appeal (Virginia, Colorado, Connecticut, Texas, Oregon and certain other states). If we decline to take action on a request, you may appeal that decision by replying to the response email or by writing to privacy@ortex.com with the subject line “Privacy Rights Appeal”. If your appeal is denied, you may contact your state’s attorney general.

“Shine the Light” (California Civil Code § 1798.83). California residents may request, once per calendar year, information about the categories of personal information (if any) we disclosed to third parties for those third parties’ direct marketing purposes. To make such a request, contact us at privacy@ortex.com.

Financial incentives. We do not offer financial incentives or price or service differences in exchange for the collection, sale or deletion of personal information.