Privacy Policy

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AFPR — Andrew Finkle's Pattern Recognition ("AFPR", "we", "us") is an educational technical-analysis publishing service operated by Andrew Finkle. This policy explains what personal information we collect when you use afpr.com, why we collect it, and the rights you have over it. Questions about this policy, or any request under it, go to andy@afpr.com.

This website has no member accounts. You do not create an account, sign in, or pay on this site, and we do not hold passwords, watchlists, member comments, or billing records for this site.

Information we collect
- Email-list signups: the name (if you provide it), email address, and investor type (professional or individual) you enter on the home-page email capture form.
- Beta access requests: the name (optional) and email address you enter on the Tools (BETA) page form, so we can check it against the Annualize This subscriber list and respond.
- Institutional applications: the information you provide in the institutional application form, including firm type and portfolio range, if you provide them.
- Technical information: the cookies and browser storage described in our Cookie Policy, and standard server logs (IP address, browser type, pages visited, timestamps) kept for security and operations.

How we use it
- To send the email you asked for: AFPR updates for email-list subscribers.
- To review beta requests and institutional applications and respond to them.
- To keep the service secure, prevent fraud and abuse, and understand, in aggregate, which parts of the site visitors use, so we can improve it.

Where the GDPR or UK GDPR applies, our legal bases are: performance of our contract with you where applicable, our legitimate interests (security and service improvement), your consent (email list and optional cookies), and compliance with legal obligations (tax and accounting records).

Who we share it with
We share personal information only with the service providers who run this website with us, and only what each needs to do its job: our hosting provider, GoDaddy, and the email and form providers that deliver form submissions and list email. These processors may not use your information for their own purposes. We may also disclose information when the law requires it, or to protect our rights and our visitors' safety.

We do not sell personal information, and we do not share it for cross-context behavioral advertising. There is no advertising on AFPR.

Email and unsubscribing
Every marketing email carries an unsubscribe link; using it stops list email for that address. If anything keeps arriving after you have unsubscribed, write to andy@afpr.com and we will fix it.

Your rights
If you are in the EU/EEA or the UK, you have the right to: access the personal information we hold about you; have it corrected (rectification); have it deleted (erasure); receive it in a portable, machine-readable format (portability); object to processing based on legitimate interests; restrict processing in certain cases; and withdraw consent at any time where processing rests on consent. You may also complain to your local data protection authority — but we would rather you wrote to us first so we can put it right.

If you are a California resident, the CCPA/CPRA gives you the right to: know what personal information we collect, use, and disclose; delete your personal information (subject to legal exceptions); correct inaccurate information; and not be discriminated against for exercising these rights. As stated above, we do not sell or share personal information as those terms are defined in California law, so there is no sale to opt out of.

To exercise any right, write to andy@afpr.com and we will respond within the time the applicable law allows (generally 30 days under the GDPR/UK GDPR and 45 days under the CCPA/CPRA). We may need to verify your identity before acting on a request; we will only ask for what is needed to do that.

Retention
We keep form submissions and email-list records until you unsubscribe or ask us to delete them, and as long as needed to respond to your request or application. Server logs are kept for security and operations and age out on a rolling basis. Backups age out on a rolling basis.

Security and children
We take reasonable technical and organizational measures proportionate to a publishing service of our size. No system is perfectly secure. AFPR is a professional service and is not directed at children under 16.

Changes to this policy
If we change this policy materially, we will update the date above and, where the change affects visitors directly, we will say so on the site or by email before the change takes effect.