Privacy Policy

Last Updated: 2026-09-15

1. Who We Are

Resolve Inc. ("we," "us," or "our") operates Pinary (https://pinary.app) (the "Service"). This Privacy Policy explains how we collect, use, disclose, and protect your personal information.

Data Controller: Resolve Inc., Shibuya Dogenzaka Tokyu Building 2F-C, 1-10-8 Dogenzaka, Shibuya-ku, Tokyo 150-0043, Japan Representative: Yo Nakajima, Representative Director Contact: [email protected]

2. Information We Collect

2.1 Information You Provide

• Account information (email address, display name)
• Onboarding preferences (trading experience level, preferred style, goals)
• Trading strategy content (strategy names, configurations, indicator parameters)
• Text prompts, text you type into the AI features, and the strategy configuration those features act on
• Payment information (processed by our reseller and its payment service providers; we do not store full card numbers; we store the customer and subscription identifiers they issue)
• Contact form submissions (name, email, message body — forwarded via email only, not stored in our database)
• Referral code usage

2.2 Information Collected Automatically

• Usage metrics (how often you use particular features)
• Authentication session cookie
• Device and browser information (IP address, browser type, operating system)
• Bot prevention risk scores and tokens

2.3 Information from Third Parties

• Authentication provider: When you sign in with a social login or email/password, we receive your email address and unique identifier from our authentication provider (United States).
• Reseller: Subscription status and payment event notifications.

2.4 Information Collected by the Chrome Extension

If you use a Pinary browser extension for TradingView:

• The Extension accesses your authentication cookie from pinary.app to authenticate you.
• The Extension reads TradingView page elements to apply strategies.
• The Extension communicates with pinary.app and tradingview.com only.
• The Extension does NOT collect browsing history, keystrokes, or data from any site other than TradingView.

3. How We Use Your Information

We use your information for the following purposes:

(a) To provide, maintain, and improve the Service; (b) To manage subscriptions and receive transaction status from our reseller; (c) To communicate with you about the Service (updates, security alerts, support); (d) To analyze usage patterns and improve user experience; (e) To detect and prevent fraud, abuse, or violations of our Terms; (f) To comply with legal obligations; (g) To generate trading strategies using AI (your text prompts and the settings of the strategy concerned are sent to our AI processing provider, based in the United States); (h) To run backtesting simulations on your trading strategies; (i) To manage your subscription, referral rewards, and coupon entitlements; (j) To prevent bot abuse via our bot prevention service; (k) To track feature usage, in order to award referral and sharing benefits and to apply plan limits.

4. Legal Basis for Processing (EEA/UK Users)

If you are in the European Economic Area (EEA) or the United Kingdom, our legal bases for processing your personal data are:

• Contract: Processing necessary to perform our contract with you (e.g., providing the Service, managing your account and subscription, processing payments, generating trading strategies).
• Legitimate Interest: Processing necessary for our legitimate interests (e.g., improving the Service, preventing fraud and abuse, enforcing plan limits and quotas), where these interests are not overridden by your rights.
• Consent: Where you have given consent (e.g., marketing communications, placing non-essential cookies). You may withdraw consent at any time.
• Legal Obligation: Processing necessary to comply with applicable laws (e.g., tax reporting, responding to lawful requests, data breach notification).

5. Sharing and Disclosure

We do not sell your personal information. We may share information with:

• Service Providers: Third parties that assist us in operating the Service, including:

  1. Reseller (United States) — Sale and payment processing. Data shared: email, subscription plan, payment method tokens.
  2. Authentication provider (United States) — User authentication via social login and email/password. Data shared: email address, authentication tokens.
  3. Content delivery and edge network provider (United States) — Serving the site and market data files, and blocking traffic from restricted regions. Data shared: IP address, request metadata.
  4. Cloud infrastructure provider (United States) — Hosting and data storage. All user data is processed and stored on this provider's infrastructure.
  5. AI processing provider (United States) — AI-assisted strategy drafting, explanation, and improvement suggestions. Data shared: the text you type into those features, and the configuration of the strategy you ask about. Data submitted via the API is not used for model training per the provider's API terms.
  6. Email delivery provider (United States) — Contact form email delivery (transient; not stored by Pinary) and mailing lists. If you sign up for a waiting list or product announcements, your email address is stored with this provider until you unsubscribe.
  7. Bot prevention provider (United States) — Bot prevention. Data shared: browser metadata, interaction patterns.

• Legal Requirements: When required by law, regulation, legal process, or governmental request.

• Business Transfers: In connection with a merger, acquisition, or sale of assets, with notice to you.

• With Your Consent: When you have explicitly agreed to the disclosure.

6. International Data Transfers

Your information may be transferred to and processed in Japan and other countries where our service providers operate (including the United States). These countries may have different data protection laws than your jurisdiction. Specifically, your data may be transferred to the United States, where our service providers (including our payment, infrastructure, and AI providers) operate, and processed there.

For transfers from the EEA/UK, we rely on appropriate safeguards such as the European Commission's adequacy decision for Japan, Standard Contractual Clauses (SCCs), or other legally recognized mechanisms.

7. Cookies and Tracking Technologies

We use cookies and similar technologies for the following purposes:

• Essential cookies — Required to operate the Service, including maintaining your authentication session, preventing fraud during payment, and bot prevention.
• Functional cookies — Used to remember choices you make, such as a referral link you arrived through.

We do not currently use analytics or advertising cookies. If we introduce them, we will update this Policy and, where required, obtain consent first.

The specific cookie names, durations, and providers may change over time as we update the Service.

For EU users, we obtain consent before placing non-essential cookies in accordance with the ePrivacy Directive.

You can control cookies through your browser settings. Disabling certain cookies may affect the functionality of the Service.

8. Data Retention

We retain personal information for as long as necessary to provide the Service, comply with legal obligations, and resolve disputes. Specific retention periods may be set out in supplementary documentation.

When you delete your account, we remove the information that directly identifies you. Records that no longer identify you may be retained for service operations, analytics, and legal or accounting requirements. Information held by third-party providers (such as our reseller) is retained according to their own retention policies and applicable law.

9. Your Rights

9.1 All Users

You may request access to, correction of, or deletion of your personal information by contacting us at [email protected], or by deleting your account from the Settings page.

9.2 EEA/UK Users (GDPR)

Under the GDPR, you have the right to:

(a) Access your personal data and receive a copy; (b) Rectify inaccurate or incomplete data; (c) Erase your data ("right to be forgotten"); (d) Restrict processing of your data; (e) Data portability (receive your data in a structured, machine-readable format); (f) Object to processing based on legitimate interests; (g) Withdraw consent at any time (without affecting the lawfulness of prior processing).

To exercise data portability, we can provide your strategies, backtest results, and account data in JSON format upon request.

You also have the right to lodge a complaint with your local data protection authority.

9.3 California Residents (CCPA/CPRA)

Under the California Consumer Privacy Act (as amended by the CPRA), California residents have the right to:

(a) Know what personal information we collect, use, and disclose; (b) Delete personal information we hold about you; (c) Correct inaccurate personal information; (d) Opt out of the sale or sharing of personal information (we do not sell your data); (e) Not be discriminated against for exercising your rights.

Opt-Out Preference Signals. We honor the Global Privacy Control (GPC) and similar browser-based opt-out preference signals. Because we do not sell or share personal information as those terms are defined under the CCPA/CPRA, these signals do not change how we handle your data; however, we will continue to honor them should our practices change.

To exercise these rights, contact us at [email protected]. We will verify your identity before processing your request. You may also designate an authorized agent to make requests on your behalf.

Categories of Information Collected: Identifiers (email, display name), commercial information (subscription history, referral activity), internet activity (usage metrics, pages visited), and inferences drawn from the above (onboarding preferences).

Business Purpose: Providing the Service, fraud prevention, and legal compliance.

9.4 Japanese Residents (APPI)

Under the Act on the Protection of Personal Information (APPI), you may request disclosure, correction, deletion, or suspension of use of your personal information. Requests can be made to the contact address in Section 13.

10. Security

We implement industry-standard security measures to protect your personal information, including:

• All data in transit encrypted via TLS 1.2+
• Data at rest encrypted on our cloud infrastructure
• Secure session cookie-based authentication
• Webhook signature verification for payment events
• No full credit card numbers stored on our systems

However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. Children's Privacy

The Service is intended for users aged 16 and older and is not directed at children under 16. We do not knowingly collect personal information from anyone under 16. If you believe a child under 16 has provided us with personal information, please contact us and we will delete it.

12. AI Data Processing

Pinary uses a third-party artificial intelligence service (based in the United States) to generate trading strategies based on your inputs.

What is sent to the AI:

• Text prompts you type
• Settings of the strategy concerned

What is NOT sent to the AI:

• Your email address or account credentials
• Your payment information
• Your browsing history or cookies

How the AI provider handles your data: Our AI provider's API terms stipulate that data submitted via the API is not used to train their AI models. The provider's privacy policy is available upon request.

AI output disclaimer: AI-generated trading strategies are provided for informational purposes only. They do not constitute financial advice. You are solely responsible for any trading decisions made using the Service.

13. Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights, please contact us at:

Resolve Inc. Shibuya Dogenzaka Tokyu Building 2F-C, 1-10-8 Dogenzaka, Shibuya-ku, Tokyo 150-0043, Japan Email: [email protected]

For EEA/UK users: If you are not satisfied with our response, you have the right to lodge a complaint with your local supervisory authority.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on the Service and, where required by law, by email. The updated policy takes effect on the date indicated at the top of this document.

Effective: 2026-09-15 (previously 2026-09-14)

The 2026-09-06 revision corrects descriptions of the Service that no longer matched it: plan limits, what happens to your data when you delete your account, the categories of usage data we collect, the providers that receive it, and the licence users grant each other.