Privacy Policy

Collected via Clerk when you sign up for an Account:

• Full name
• Email address
• Password (encrypted by Clerk; we cannot view it)
• Profile preferences and settings
• Account creation date and login activity

Processed by Stripe when you subscribe to the Service:

• Billing name and address
• Payment card details (processed directly by Stripe; we do not see or store full card numbers)
• Subscription tier and billing cycle
• Transaction history and invoices
• Stripe Identity verification documents (where collected for age verification)

Generated automatically when you use the Service:

• Pages and features you access within the Terminal
• Workspace configurations, saved layouts, and preferences
• Session timestamps and activity duration

• IP address
• Browser type and version
• Operating system and device type
• Referring URL
• Time zone and approximate geographic location (city or region level)

If you join our Discord community server, we and Discord process:

• Discord username and user ID
• Messages you post in our Discord server
• Roles, reactions, and channel participation

You can leave the Discord server at any time. Joining is optional and not required to use the Terminal.

• Emails you send to us and our replies
• Support tickets and queries
• Marketing email engagement (opens, clicks, unsubscribes) if you opt in to marketing communications

• Whether you have opted in to receive Division1 product updates
• Whether you have opted in to receive michikofx.com updates and announcements
• Date and time of your consent
• Records of any withdrawal of consent

We do notcollect any special category data (sometimes called "sensitive personal data") under UK GDPR Article 9, including racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data, health data, or data concerning sexual orientation. The Service does not require or request this information.

We need to process certain personal data to provide the Service you have subscribed to. This includes:

• Creating and managing your Account
• Providing access to the Terminal and its features
• Processing your subscription payments via Stripe
• Sending you transactional emails (subscription confirmations, billing receipts, password resets, security notices, and service-critical announcements)
• Providing customer support

We rely on our legitimate interests to:

• Operate, maintain, secure, and improve the Service
• Detect, prevent, and respond to fraud, abuse, security threats, and breaches of our Terms
• Conduct anonymous, aggregated analytics about how the Service is used (using cookieless analytics tools)
• Defend our legal rights and resolve disputes
• Communicate with you about your Account and our Service for non-marketing purposes

In each case, we have weighed our legitimate interests against your rights and freedoms, and we believe our processing does not override those rights. You have the right to object to processing on this basis at any time. See Section 10.

We process certain data to meet legal obligations, including:

• Maintaining accounting and tax records under UK law (Companies Act 2006, Finance Acts, HMRC requirements)
• Verifying that users are 18 years of age or older, via Stripe Identity where required
• Responding to lawful requests from regulators, courts, or law enforcement
• Complying with court orders

We rely on your specific, informed, opt-in consent to:

• Send you Division1 product updates and marketing communications
• Send you michikofx.com updates and announcements

You may withdraw either or both consents at any time. See Section 5 for details. Withdrawal does not affect the lawfulness of processing before withdrawal.

We will only send you marketing emails if you have given us your specific, opt-in consent. Pre-ticked boxes are not used.

When you create an Account, you may choose to opt in to one or both of the following separate communication streams:

• Division1 updates - product announcements, new features, market commentary, and Division1 promotions
• michikofx.com updates- broader communications from Michiko's wider platform, including educational content and michikofx.com news

Each consent is separate and specific. Opting in to one does not opt you in to the other.

You can withdraw either or both marketing consents at any time:

• By clicking "unsubscribe" in any marketing email
• By updating your preferences in your Account settings (where available)
• By emailing michiko@michikofx.com

Withdrawal takes effect promptly. You may continue to receive transactional emails (billing receipts, security notices, service-critical announcements) for as long as you have an active Account, because these are sent on the basis of contract performance, not marketing consent.

When we send marketing communications, we use Kit(formerly known as ConvertKit, operated by Kit, Inc.) as our email service provider. Kit processes your email address and engagement data (opens, clicks, unsubscribes) on our behalf as a data processor. Kit's privacy policy is available at https://kit.com/privacy.

These cookies are essential for the Service to function. Under the UK Privacy and Electronic Communications Regulations (PECR), we do not need your consent to use them. They include:

• Authentication cookies set by Clerk to keep you logged in
• Session cookies set by Supabase and the Terminal to remember your current session
• Payment cookies set by Stripe during checkout to process your payment securely

We use Vercel Web Analytics and Vercel Speed Insights to understand how the Service is used and to monitor performance. These tools are cookieless and anonymous by design. They do not store personal identifiers in your browser and do not use cookies or local storage to track individuals across sessions or websites.

Because Vercel's analytics are cookieless and anonymous, no cookie consent banner is required for them, and no specific consent is needed before they run.

Vercel's privacy policy is available at https://vercel.com/legal/privacy-policy.

We do not use any tracking cookies, advertising cookies, or third-party tracking pixels. We do not run advertising on the Service. We do not sell, share, or otherwise make your personal data available to advertisers.

If we ever add cookies that require your consent under PECR (for example, marketing tracking or third-party advertising), we will update this Policy and present you with a cookie consent banner before setting any such cookies.

We use the following service providers to operate the Service. Each is bound by a data processing agreement where required by UK GDPR Article 28 and operates under their own published privacy policies.

• Clerk - authentication and account management (United States)
• Stripe - payment processing and identity verification (United States)
• Supabase - database hosting and server infrastructure (United States or EU, region-dependent)
• Vercel - web hosting, edge delivery, and anonymous analytics (United States)
• Kit (formerly ConvertKit) - marketing email delivery, when active (United States)
• Discord - community server hosting, if you join (United States)
• Cloudflare (planned) - edge security, DDoS protection, and rate limiting (United States)

We may add or change service providers from time to time. Material changes to our list of processors will be reflected in this Policy.

We may disclose your personal data:

• To comply with a legal obligation, court order, or lawful request from a regulator or law enforcement body
• To enforce our Terms of Service or other agreements
• To protect the rights, property, or safety of Michiko Academy Ltd, our users, or others
• To investigate fraud, security incidents, or other unlawful activity

If Michiko Academy Ltd is involved in a merger, acquisition, asset sale, restructuring, or insolvency proceeding, your personal data may be transferred to the relevant party. We will notify affected users in advance and give you a reasonable opportunity to object before your data becomes subject to a different privacy policy.

We do not sell your personal data to any third party for advertising, marketing, profiling, or any other purpose.

You can request a copy of the personal data we hold about you, together with information about how we use it. This is often called a Subject Access Request or SAR.

You can ask us to correct any inaccurate or incomplete personal data we hold about you.

You can ask us to delete your personal data in certain circumstances, including where the data is no longer needed for the purposes for which it was collected, where you withdraw your consent, or where you object to processing. Some data must be kept under legal obligations (for example, tax records held by Stripe under HMRC requirements).

You can ask us to stop using your data in certain circumstances, for example while we investigate a complaint or dispute about its accuracy.

You can request a copy of the personal data you have provided to us in a structured, commonly used, machine-readable format, and ask us to transmit it to another data controller where technically feasible.

You can object to our processing of your personal data on the basis of legitimate interests (Section 4.2 above), and to direct marketing at any time. We will stop processing for direct marketing immediately on your request.

Where we rely on your consent (for marketing communications), you can withdraw your consent at any time. Withdrawal does not affect the lawfulness of any processing carried out before withdrawal.

We do not make automated decisions about you that produce legal or similarly significant effects. The Service produces analytical signals about foreign exchange markets, not decisions about you as an individual. You are not subject to automated profiling that affects your legal rights or significantly impacts you. The trading bias signals, conviction scores, and other outputs of the Terminal are tools for your own analysis. Any trading decisions are made by you, not by us.

To exercise any of your rights, please email michiko@michikofx.com.

We will respond within one month of receiving your request. This period may be extended by up to two further months for complex requests, in which case we will tell you within the first month and explain why.

We may need to verify your identity before responding to your request, to protect your data from unauthorised disclosure. We will not charge you a fee unless your request is manifestly unfounded or excessive.

If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the UK Information Commissioner's Office:

We would appreciate the chance to address your concerns directly before you contact the ICO. Please email michiko@michikofx.com first if you have any concerns; we will do our best to resolve them.