Privacy Policy

1. Preamble

Sun-BD (the "Company") respects your privacy. This Privacy Policy explains how we collect, use, protect, and share your personal data. By using this website or the software services we provide, you agree to the terms of this Policy. Personal data is processed by Sun-BD Co., Ltd. as data controller (Republic of China / Taiwan).

2. Scope of Data Collection

We may collect the following categories of data:

• Account information: email address, user name
• Device information: device type, operating system version, app version
• Usage data: feature usage frequency, preferences, error reports
• Trading-related: strategy parameters you configure (does not include actual brokerage account information)

3. Purpose of Use

Collected data is used for the following purposes:

• Providing and improving the Company's software services
• System maintenance, troubleshooting, and security protection
• Analyzing usage patterns to optimize product experience
• Sending essential system notifications (version updates, security alerts)

4. Data Protection Measures

The Company takes reasonable technical and organizational measures to protect your personal data:

• Data transmission uses SSL/TLS encryption
• Server access is subject to strict permission control
• Regular security audits and vulnerability scans are conducted
• Employees are bound by data confidentiality obligations

5. Data Sharing

The Company does not sell your personal data. We may share data only in the following situations:

• With your explicit consent
• When required by law or government agency under legal process
• When necessary to protect the rights of the Company or its users

No personal data is sold; sharing is limited to processors under contractual safeguards (Article 28 GDPR / UK DPA 2018 Schedule 1).

6. Cookies and Tracking Technologies

This website is a purely static site and currently does not use cookies or third-party tracking technology. Should this change in the future, this Policy will be updated and users will be notified.

7. Your Rights

Pursuant to the EU General Data Protection Regulation (GDPR) and, for UK consumers, the UK GDPR (as retained in UK law by the European Union (Withdrawal) Act 2018) read alongside the UK Data Protection Act 2018, you have the following rights regarding your personal data:

• Right of access (EU GDPR Art 15 / UK GDPR Art 15): obtain confirmation of processing and a copy of your personal data
• Right to rectification (EU GDPR Art 16 / UK GDPR Art 16): correct inaccurate or incomplete personal data
• Right to erasure ("right to be forgotten") (EU GDPR Art 17 / UK GDPR Art 17): request deletion under specified conditions
• Right to restriction (EU GDPR Art 18 / UK GDPR Art 18): limit processing under specified conditions
• Right to data portability (EU GDPR Art 20 / UK GDPR Art 20): receive your data in a structured, machine-readable format and transmit it to another controller
• Right to object (EU GDPR Art 21 / UK GDPR Art 21): object to processing based on legitimate interests or for direct marketing
• Rights related to automated decision-making (EU GDPR Art 22 / UK GDPR Art 22): not be subject to solely automated decisions producing legal effects
• Right to withdraw consent (EU GDPR Art 7(3) / UK GDPR Art 7(3)): withdraw previously given consent at any time

To exercise any of these rights, please contact contact@sun-bd.com. We will respond within one month as required by EU GDPR Article 12(3) / UK GDPR Article 12(3).

8. Cross-Border Data Transfers

Sun-BD Co., Ltd. is established in the Republic of China (Taiwan), which is not an "adequate" jurisdiction under GDPR Article 45 or UK DPA 2018 Schedule 21 paragraph 4. Personal data transferred from the European Economic Area (EEA) or the United Kingdom to the Republic of China (Taiwan) for service provision is therefore subject to Standard Contractual Clauses (SCCs) approved by:

• the European Commission pursuant to GDPR Article 46(2)(c) (Implementing Decision (EU) 2021/914)
• the UK Information Commissioner's Office pursuant to UK DPA 2018 Schedule 21 paragraph 5 (UK International Data Transfer Agreement / Addendum)

By using the Service from the EEA or the UK, you acknowledge such cross-border transfer. We implement supplementary technical and organisational measures, including encryption in transit and at rest, access controls, and audit logging, consistent with the Schrems II standard.

9. Supervisory Authorities

EEA consumers may lodge complaints regarding the processing of their personal data with their local Data Protection Authority pursuant to GDPR Article 77. UK consumers may lodge complaints with the Information Commissioner's Office (ICO) pursuant to the UK Data Protection Act 2018. Exercising this right does not affect any other administrative or judicial remedy available to you.

10. Policy Revisions

The Company reserves the right to revise this Privacy Policy at any time. Material changes will be announced on the website or via email. We recommend you review this page periodically to stay informed of the latest policy.

11. Disclaimer

Analytical results and trading signals provided by this system are for reference only and do not constitute investment advice. Trading in stocks, futures, and derivative financial instruments involves high risk and may result in loss of principal. Past performance does not guarantee future results. Investors should carefully evaluate their financial condition and bear their own investment risk.

Note: In the event of any inconsistency between the English and Chinese versions, the Traditional Chinese version shall prevail.