Tenkay Privacy Policy

We take data privacy seriously and are committed to protecting your personal information and intellectual property. In compliance with the EU General Data Protection Regulation (GDPR), this privacy policy outlines what personal data we collect, how we use it, and your rights regarding your data. The policy applies to our website, application, and Microsoft add-ins including Tenkay Model Updater.

Our clients trust us with two kinds of sensitive information:

- Personally Identifiable Information (PII), as described in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context.

- Proprietary Financial Projections represent sensitive intellectual property in the asset management industry and are considered extremely sensitive for our clients, on their own or in combination with PII.

This Privacy Policy outlines when we do or do not collect each kind of information, what we do with it, and how long we keep it.

What PII do we collect?

We collect personal data that you provide to us voluntarily, such as your name and email address when you sign up for access or when you fill out a contact form. We also collect data about your usage of our website and applications through cookies and analytics tools.

When do we collect PII?

We collect information from you when you or enter information in a form on our website or add-in.

How do we use your PII?

We use your personal data to provide you with the information, products, or services you have requested from us, such as product updates. We may also use your data to improve our website and services or to comply with legal obligations.

How long do we retain PII?

We retain your Personal Information for as long as is reasonably necessary to provide services to you, for our legitimate business purposes, and to comply with our legal and regulatory obligations. If you close your account with us, we will continue to retain your Personal Information as necessary to comply with our legal and regulatory obligations, including for fraud monitoring, detection and prevention, and for our tax, accounting, and financial reporting obligations.

What Proprietary Financial Projections do we collect?

When used as directed, our add-ins do not store any financial projections or relay them to our servers. Any calculations based on future projections are performed within the clients Excel file and remain their exclusive property.

Our servers do receive historical information from your financial models, which improves our ability to provide the correct values back to you. Because these values have already been publicly reported, we do not consider them proprietary or sensitive.

How do we take payment for our services?

We process all financial transactions through a gateway and will never ask for a credit card or bank account information directly, or store this data on our servers.

Do we share your data with Third-parties?

We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information.

How do we train our AI models?

We use stored user queries in development and testing as we strive to make our products as accurate and user-friendly as possible. The queries that are sent to our API partners use Tenkays API keys and therefore keep our clients identities private. Furthermore, according to our partners privacy policies, our queries are not used for training purposes.

For more specifics on how queries sent on your behalf will be used by our AI partners, please refer to the API privacy policies for OpenAI, Google Gemini, and Anthropic Claude.

California Online Privacy Protection Act

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The laws reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared.

According to CalOPPA, we agree to the following:

Users can visit our site anonymously.

Once this privacy policy is created, we will add a link to it on our home page or as a minimum, on the first significant page after entering our website.

Our Privacy Policy link includes the word Privacy and can be easily be found on the page specified above.

You will be notified of any Privacy Policy changes:

- On our Privacy Policy Page

Can change your personal information:

- By emailing us

How does our site handle Do Not Track signals?

We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

Does our site allow third-party behavioral tracking?

We do not allow third-party behavioral tracking

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under the age of 13 years old, the Childrens Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect childrens privacy and safety online.

Our product is not intended for or specifically marketed to children under the age of 13 years old.

Fair Information Practices

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:

We will notify you via email within 7 business days

We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

- Send information, respond to inquiries, and/or other requests or questions

To be in accordance with CANSPAM, we agree to the following:

- Not use false or misleading subjects or email addresses.

- Identify the message as an advertisement in some reasonable way.

- Include the physical address of our business or site headquarters.

- Monitor third-party email marketing services for compliance, if one is used.

- Honor opt-out/unsubscribe requests quickly.

- Allow users to unsubscribe by using the link at the bottom of each email.

To unsubscribe from future emails, email us at privacy@tenkay.ai