globalbarry. Company Intelligence Engine
Draft — pending counsel review. This document is a baseline draft that has not yet been reviewed by legal counsel. Bracketed items such as [Company Legal Name] are placeholders to be completed before publication.

Privacy Policy

Effective date: [Effective Date] · Last updated: [Last Updated Date]

1. Who we are

Global Barry (the "Service") is operated by [Company Legal Name], a company organized under the laws of [Jurisdiction] with its registered address at [Registered Address] ("we", "us", "our"). This Privacy Policy explains what personal information we collect when you use the Service, how we use it, and the choices and rights available to you. For the purposes of applicable data-protection law, [Company Legal Name] is the controller of the personal information described here.

2. Information we collect

2.1 Information you provide

  • Account information: email address, display name and a password (stored only as a salted one-way hash, never in plain text).
  • Workspace content: watchlists, portfolios, holdings, cost-basis figures, alert rules, notes and questions you submit to AI features such as the Research Copilot or Exposure Analysis.
  • Billing information: plan selection and billing history. Payment card details are collected and processed by our payment processor, [Payment Processor Name], and are not stored on our servers.
  • Communications: messages you send to us, such as support requests or security questionnaires.

2.2 Information collected automatically

  • Session and security data: session identifiers, CSRF tokens and authentication cookies needed to keep you signed in and protect your account (see our Cookie Policy).
  • Usage and technical data: pages and features used, API requests made with your API keys, request timestamps, IP address, browser type and device information, and error logs.
  • AI usage records: metadata about AI requests (for example, feature used, timing and whether a cached result was served) for cost accounting, abuse prevention and quality control.

2.3 Public-source data

The intelligence content of the Service is built from publicly available sources, such as regulatory filings, government statistical releases and official corporate disclosures. This content describes companies, markets and economic conditions; it is not personal information about you.

3. How we use information

  • To provide, operate and maintain the Service, including your account, watchlists, portfolios, alerts and AI-assisted research.
  • To authenticate you, secure accounts, and detect, prevent and investigate fraud, abuse and security incidents.
  • To send transactional messages such as email verification, password resets, alert notifications you configure, and service or policy notices.
  • To administer subscriptions, entitlements, usage limits and billing.
  • To monitor performance, troubleshoot problems and improve the Service.
  • To comply with legal obligations and enforce our Terms of Service.

We do not sell your personal information. We do not use your portfolios, watchlists or holdings to train global or foundation AI models. When you use an AI feature, the relevant content is sent to our inference provider transiently to generate a response.

Where the law requires a legal basis for processing, we rely on: performance of our contract with you; our legitimate interests in operating and securing the Service; compliance with legal obligations; and your consent where it is required (which you may withdraw at any time). [Counsel to confirm legal bases by jurisdiction.]

4. Cookies and similar technologies

We use cookies that are strictly necessary for the Service to function, such as session, authentication and CSRF-protection cookies. Details of each category and how to control cookies are in our Cookie Policy.

5. Third-party processors

We share personal information only with service providers that process it on our behalf under written agreements that restrict their use of the data to providing services to us. Categories of processors include:

  • Cloud hosting and database infrastructure: [Hosting Provider Name]
  • AI model inference: [AI Inference Provider Name]
  • Transactional email delivery: [Email Delivery Provider Name]
  • Payment processing: [Payment Processor Name]

We may also disclose information if required by law, regulation or valid legal process; to protect the rights, property or safety of our users, the public or us; or in connection with a merger, acquisition or sale of assets, in which case we will require the recipient to honor this Policy. A current list of sub-processors is available on request at [Contact Email].

6. Your rights

Depending on where you live, you may have the following rights regarding your personal information:

  • Access: request a copy of the personal information we hold about you.
  • Correction: update inaccurate or incomplete information. You can change your email address and display name in your account settings.
  • Deletion: request that we delete your account and associated personal information, subject to limited retention required by law.
  • Export (portability): receive your workspace content, such as watchlists and portfolios, in a structured, machine-readable format.
  • Objection and restriction: object to or ask us to restrict certain processing.
  • Withdraw consent: where processing is based on consent, withdraw it at any time without affecting prior processing.
  • Complain: lodge a complaint with your local data-protection authority.

To exercise these rights, contact us at [Contact Email]. We will verify your identity before acting on a request and respond within the time required by applicable law. We will not discriminate against you for exercising your rights.

7. Data retention

We keep account information and workspace content for as long as your account is active. After you delete your account, we delete or anonymize your personal information within [Retention Period] days, except where we must keep it longer to meet legal, tax, accounting or security obligations, resolve disputes or enforce our agreements. Security and access logs are retained for up to [Log Retention Period]. Single-use tokens, such as email-verification and password-reset links, expire automatically.

8. Security

We use administrative, technical and organizational measures designed to protect personal information. These include encryption in transit (HTTPS), one-way hashing of passwords, session tokens and API credentials, CSRF protection on state-changing requests, and access controls on administrative functions. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. More detail is available in our Trust Center.

9. International transfers

We and our processors may store and process information in [Primary Data Location] and other countries whose data-protection laws may differ from those where you live. Where required, we rely on appropriate safeguards for such transfers, such as standard contractual clauses approved by the relevant authorities. [Counsel to confirm transfer mechanisms.]

10. Children

The Service is not directed to individuals under [Minimum Age], and we do not knowingly collect personal information from them. If you believe a child has provided us with personal information, contact us and we will delete it.

11. Changes to this Policy

We may update this Policy from time to time. If we make material changes, we will notify you by email or through the Service before they take effect, and we will update the effective date above.

12. Contact

Questions or requests about this Policy can be sent to [Contact Email], or by mail to [Company Legal Name], [Registered Address]. Where applicable, our data-protection representative can be reached at [DPO / Representative Contact].