Privacy Policy

Last updated: February 2026

This Privacy Policy describes how Scydex Ltd, parent company of Portfolio Guardian (“Portfolio Guardian,” “we,” or “us”) collects, uses, discloses, and otherwise processes information about you. This Privacy Policy applies to information we collect when you access or use our mobile application, websites, and other online products and services that link to this Privacy Policy (collectively, our “Services”) and when you otherwise interact with us, such as through our customer support channels, on social media, or at our events.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. If we make material changes, we may provide you with additional notice (such as by adding a statement to the Services or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

Contents

• Collection of Information
• Use of Information
• Disclosure of Information
• Data Retention
• Your Choices
• Your Rights
• Additional Information for Individuals in Europe
• Contact Us

Collection of Information

The information we collect about you depends on how you interact with us. In this section, we describe the categories of information we collect and the sources of this information.

Information You Provide to Us

We collect information you provide directly to us. For example, we collect information directly from you when you create an account, subscribe to our Services, add tickers to your watchlist, set Sentinel alerts, or otherwise communicate with us. Depending on which Services you use, the types of information that we collect directly from you include your name, email address, and any other information you choose to provide.

Information We Collect Automatically

We automatically collect information about your interactions with us or our Services, including:

Device, Usage, and Activity Information: We collect information about how you access our Services, including data about the device and network you use, such as your device’s operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, unique identifiers, connection information, language settings, and general location information such as city, state, or geographic area. We also collect information about your activity on our Services, such as tickers searched, watchlist activity, and features used.

Push Notification Tokens: If you enable push notifications (including Sentinel alerts), we collect your device push notification token to deliver notifications to your device. You can disable push notifications at any time through your device settings.

Information Collected by Cookies and Similar Tracking Technologies: We use cookies and similar tracking technologies to operate and provide our Services, as well as to collect information about your interactions with the Services. For example, these technologies help us remember your preferences and analyse your interactions with us.

Subscription and Payment Information

When you subscribe to Portfolio Guardian, your purchase is processed through Apple’s App Store or Google Play Store via RevenueCat, our subscription management provider. We do not directly collect or store your payment card details. We receive confirmation of your subscription status, purchase date, and entitlement information from RevenueCat to manage your access to paid features.

Information We Collect from Other Sources

We obtain information from other sources. For example, if you create or log into your account through a third-party platform (such as Google, Facebook, or Apple), we will have access to certain information from that platform, such as your name, email address, and any other information the third-party platform discloses about you, in accordance with the authorisation procedures determined by such platform.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address.

Use of Information

We use the information we collect to:

• Provide, maintain, and improve the Services, including delivering market structure analysis, managing your watchlist, and processing Sentinel alerts;
• Develop new products and services;
• Personalise your experience with us;
• Send you technical notices, security alerts, Sentinel notifications, support messages, and other transactional or relationship messages;
• Send you marketing communications (see the Your Choices section below for information about how to opt out of these communications at any time);
• Monitor and analyse trends, usage, and activities in connection with our products and services;
• Detect, investigate, respond to, prosecute, and help protect against security incidents and other malicious, deceptive, fraudulent, or illegal activity, and help protect the rights and property of Portfolio Guardian and others;
• Comply with our legal and financial obligations;
• To carry out any other purpose described to you at the time the information was collected; and
• To create de-identified and aggregate data that cannot reasonably be linked to you.

Important: We do not engage in “sales” or “sharing” of personal information or process personal information for “targeted advertising” purposes as those terms are defined by U.S. state privacy laws or the GDPR.

Disclosure of Information

We disclose personal information as described in this Privacy Policy and in the following ways:

Vendors and Service Providers

We make personal information available to our vendors, service providers, contractors, and consultants who perform services on our behalf, such as companies that assist us with cloud computing and storage, subscription management (RevenueCat), push notification delivery, analytics, and customer support.

Law Enforcement Authorities and Individuals Involved in Legal Proceedings

We disclose personal information in response to a request for information if we believe that disclosure is in accordance with, or required by, any applicable law, regulation, or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.

To Protect the Rights of Portfolio Guardian and Others

We may disclose personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of our users, the public, or others.

Professional Advisors

We disclose personal information to our legal, financial, insurance, and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.

Corporate Transactions

We disclose personal information in connection with, or during negotiations of, certain corporate transactions, including a merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

With Your Consent or at Your Direction

We make personal information available to third parties when we have your consent or you intentionally direct us to do so.

We also disclose aggregated or de-identified information that cannot reasonably be used to identify you. We maintain and use this information only in a de-identified fashion and will not attempt to re-identify such information, except as permitted by law.

Data Retention

We store personal information associated with your account for as long as your account remains active. We store other personal information for as long as necessary to carry out the purposes for which we originally collected and processed it, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations or until you withdraw your consent (where applicable).

To determine the appropriate retention period for personal information, we consider factors such as:

• The amount, nature, and sensitivity of the personal information;
• The potential risk of harm from unauthorised use or disclosure of personal information;
• The purposes for which we use personal information and whether we can achieve those purposes through other means; and
• The applicable legal and regulatory requirements.

Your Choices

Account Information

You can access, correct, and delete certain information stored within your account at any time by navigating to your profile or settings within the app.

Communications Preferences

You may opt out of receiving promotional emails from Portfolio Guardian by following the instructions in those communications. If you opt out, we may still send you non-promotional emails, such as those about your account or Sentinel alerts you have configured.

Push Notifications

You can disable push notifications, including Sentinel alerts, at any time through your device settings.

Your Rights

Depending on where you reside, you may have the right to (1) access your personal information, including in a portable format, (2) request deletion or erasure of your personal information, (3) request correction of inaccurate personal information, (4) object to certain processing of your personal information, or (5) request we restrict certain processing. You have the right not to be discriminated against for exercising any of your privacy rights.

To exercise your rights, contact us by email at legal@scydex.com.

Appeals

If we deny your rights request, you may appeal our decision by contacting us. If you have concerns about the result of an appeal, or if we are unable to resolve your concerns about our processing of your personal data, you may contact the attorney general in the state where you reside or, if you are in Europe, lodge a complaint with the Data Protection Authority where you reside.

Authorised Agents

Depending on where you reside, you may designate an authorised agent to submit an access, deletion, or correction request on your behalf. We may ask authorised agents to submit proof of their authority to make a request, such as a valid power of attorney or proof that they have signed permission from the consumer who is the subject of the request. If you are an authorised agent seeking to make a request on behalf of a consumer, please contact us via email at legal@scydex.com.

Additional Information for Individuals in Europe

If you reside in Europe, this section applies to you.

International Transfers

Portfolio Guardian is operated by Scydex Ltd, based in the United Kingdom, and we and our service providers process and store personal information on servers located in the United Kingdom and other countries. Whenever we make restricted international transfers of personal information, we take steps to ensure that your personal information receives an adequate level of protection (by putting in place appropriate safeguards, such as contractual clauses) or ensure that we can rely on an appropriate derogation under data protection laws.

Legal Basis for Processing

We process your personal information on the following legal bases:

• Consent: Where you have given us permission (e.g., subscribing to marketing communications or enabling push notifications).
• Contractual necessity: To fulfil obligations related to your use of our Services, including managing your subscription and delivering Sentinel alerts.
• Legal obligation: To comply with applicable laws and regulations.
• Legitimate interest: To improve service delivery, analyse usage patterns, and maintain the security of our Services.

Contact Us

If you have questions about this Privacy Policy, please contact us at legal@scydex.com.

Scydex Ltd.

Email: legal@scydex.com

Office Address: 320 City Road, London, England, EC1V 2NZ

This Privacy Policy is effective as of February 2026, and applies to all users of the Portfolio Guardian application.