Privacy Policy

1. Introduction

Apact Solutions, Inc. (“Apact,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy describes how we collect, use, disclose, and safeguard information when you visit our website, use our software platform, or otherwise engage with us.

This policy applies to all users of Apact’s software and services (collectively, the “Services”) located in the United States.

Our clients are brokers and trading firms. In the course of using the Services, our clients submit trade and confirmation data that may include information about their counterparties and other third parties who are not themselves Apact users. This Policy describes how we handle that information as well. Where Apact processes such information on behalf of a client, the client is responsible for ensuring it has the right to provide that information to us, and Apact acts only as a service provider / processor under that client’s instructions.

2. Information We Collect

We collect information that identifies, relates to, describes, or could reasonably be linked with an individual or organization (“Personal Information”). This includes:

a. Information You Provide

• Account Information: Name, email address, job title, organization, and other registration data.
• Communications: Information contained in your correspondence with us, including support inquiries and demo requests.
• Trade or Transaction Data: Trade details, timestamps, counterparty information, and related OTC confirmation data uploaded or transmitted through our platform. This may include identifying information about counterparties and their personnel.

b. Automatically Collected Information

• Usage Data: Log files, IP addresses, browser type, pages visited, and access times.
• Device and Network Information: System and performance data related to your use of the Services.
• Cookies and Similar Technologies: To analyze site usage and improve user experience (e.g., via Google Analytics in future releases).

c. Information from Integrations and Third Parties

We may receive or process information through third-party systems, including:

• CRM / Marketing Tools: HubSpot.
• Analytics Providers: Google Analytics (planned).
• Cloud Providers: Amazon Web Services (AWS), Microsoft Azure, and Google Cloud Platform (GCP).
• Trading Integrations: Future integrations with ICE and other ETRM/CTRM systems for trade routing and confirmation purposes.

3. How We Use Information

Apact uses the information we collect to:

• Provide, maintain, and improve the Services;
• Authenticate users and ensure platform security;
• Facilitate trade confirmation, recordkeeping, and reporting;
• Communicate with users, including responding to inquiries and providing updates;
• Enforce our Terms of Service and policies;
• Detect, prevent, and address technical issues, fraud, or misuse;
• Analyze usage trends to enhance user experience;
• Comply with legal obligations and enforce our terms.

We do not sell or rent Personal Information to third parties. We also do not use Personal Information for cross-context behavioral advertising. We do not use trade or counterparty data for marketing purposes or for any purpose other than providing the Services and meeting legal and contractual obligations.

4. How We Share Information

We may share information as follows:

• With Service Providers: Third parties that host our infrastructure (AWS, GCP, MSFT), provide analytics (Google Analytics), or marketing support (HubSpot).
• With Integration Partners: When you authorize integrations with systems such as ICE or other ETRM/CTRM platforms.
• For Legal Compliance: If required by law, subpoena, or regulatory request.
• In Business Transfers: In connection with a merger, acquisition, financing, or sale of company assets.

All third parties are bound by confidentiality and security obligations consistent with this Policy.

We do not share one client’s trade or counterparty data with any other client. Each client’s data is logically segregated and accessible only to that client and to authorized Apact personnel who need access to operate and support the Services.

5. Data Security

Apact employs industry-standard administrative, technical, and physical safeguards to protect your data, including encryption in transit and at rest, access controls, and continuous monitoring of infrastructure. However, no online system is entirely secure. You use the Services at your own risk.

In the event of a data breach affecting your Personal Information, Apact will notify affected clients and, where required, individuals and regulators, in accordance with applicable law.

6. Data Retention

We retain Personal Information as long as necessary to provide our Services, meet legal requirements, resolve disputes, and enforce our agreements. When information is no longer needed, it will be securely deleted or anonymized.

Trade and confirmation data is retained for the period specified in our agreement with the relevant client, or as required by applicable recordkeeping and regulatory obligations, whichever is longer.

7. Your Rights and Choices

Depending on where you live, you may have some or all of the following rights with respect to your Personal Information:

• Access or update your account information;
• Request a copy of the Personal Information we hold about you;
• Request deletion or correction of your Personal Information (subject to regulatory or contractual obligations);
• Opt out of marketing communications at any time by following unsubscribe instructions in emails.

Residents of certain U.S. states may have additional rights under applicable state privacy laws. To exercise any of these rights, contact us at support@apact.ai. We will respond within the timeframe required by applicable law and will not discriminate against you for exercising your rights.

Note on counterparty data: If you are a counterparty or other third party whose information was submitted to Apact by one of our clients, that client controls that data. We will refer your request to the relevant client or assist them in responding.

8. Cookies and Tracking

We use cookies and similar technologies to enhance functionality and measure engagement. You may disable cookies in your browser, but some features of the Services may not function properly.

9. Children’s Privacy

Our Services are designed for business users and not intended for individuals under 18 years of age. We do not knowingly collect Personal Information from minors.

10. Data Storage and Processing Location

Apact stores and processes data using cloud infrastructure located in the United States. The Services are intended for users in the United States.

11. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will post the updated version with a revised “Last Updated” date. If changes are material, we will provide additional notice as required by law.

12. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact:

Apact Solutions, Inc.
Attn: Privacy / CEO
Email: support@apact.ai
Address: Delaware, USA