Privacy Policy

Gainloom (“Gainloom,” “we,” “us,” or “our”) provides portfolio allocation decision-support software (the “Service”) to institutional clients, including hedge funds, registered investment advisers (“RIAs”), and family offices. This Privacy Policy explains what information we collect, how we use it, and the choices you have.

Account information. Name, email address, firm name, role/title, and authentication credentials (including information provided via third-party sign-in providers such as Google).

Portfolio and holdings data. Information you upload to use the Service, including but not limited to: security tickers, asset classes, position weights or quantities, constraint parameters, and any other portfolio-related data you submit (“Client Data”).

Usage data. Information about how you interact with the Service, including log data, device/browser information, IP address, timestamps, and feature usage.

Communications. Information you provide when you contact us, request a demo, or otherwise communicate with us.

We use the information above to:

• Provide, operate, and maintain the Service, including running optimization computations on Client Data you submit
• Authenticate users and secure accounts
• Communicate with you about the Service, including support and administrative messages
• Monitor, debug, and improve the Service
• Comply with legal obligations
• Detect and prevent fraud, abuse, or security incidents

We do not use Client Data to make investment decisions on your behalf, and the Service does not constitute investment advice (see Terms of Service).

We do not sell Client Data. We may share information with:

• Service providers who help us operate the Service (e.g., cloud hosting, database, authentication, and analytics providers), under contractual obligations to protect it
• Legal and safety purposes, where required by law, regulation, legal process, or governmental request, or to protect the rights, property, or safety of Gainloom, our users, or others
• Business transfers, in connection with a merger, acquisition, financing, or sale of assets, subject to standard confidentiality protections
• With your consent, for any other purpose you explicitly authorize

We use commercially reasonable administrative, technical, and organizational safeguards designed to protect Client Data, including encryption in transit and at rest, access controls, and audit logging. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. See the liability limitations in our Terms of Service, which apply to any data security incident.

We retain Client Data for as long as your account is active or as needed to provide the Service, plus any additional period required to comply with legal obligations, resolve disputes, or enforce our agreements. You may request deletion of your Client Data as described in Section 8.

Client Data is hosted in the United States (AWS US regions). EU data residency is available on request for clients requiring it.

Depending on your jurisdiction, you may have rights to access, correct, delete, or export your information, or to object to or restrict certain processing. To make a request, contact us at theatikshshukla@gmail.com. We will respond consistent with applicable law. We may need to verify your identity before fulfilling a request.

The Service is intended for business use by institutional professionals and is not directed to individuals under 18. We do not knowingly collect information from children.

If you access the Service from outside the United States, you understand your information will be transferred to and processed in the United States (or other regions as disclosed above), which may have different data protection laws than your jurisdiction.

We may update this Privacy Policy from time to time. We will post the updated version with a new “Last updated” date, and, for material changes, provide additional notice as appropriate (e.g., email or in-app notice).

Questions about this Privacy Policy can be directed to: theatikshshukla@gmail.com