Privacy Policy

01

Scope of this policy

This Privacy Policy applies to services operated by Otis Execution Systems LLC, referred to in this policy as “OES,” “we,” “our” or “us.”

Covered services may include:

• The Otis Execution Systems website
• ChaseInGreen
• Lottovate
• OES mobile applications
• OES web applications and administrative tools
• OES application programming interfaces and backend services
• Customer support and business communications

Client applications developed by OES for another company may be governed by that company’s own privacy policy.

02

Information we may collect

The information collected depends on the OES service you use and the features you choose to activate.

Account and contact information

• Name
• Email address
• User identification number
• Authentication and account-status information
• Support requests and communications

Passwords may be processed by an authentication provider. OES does not need to receive or store your readable account password.

App activity and user content

• Watchlists and selected symbols
• Saved trades and trade journal entries
• Trade plans, entry prices, stops and targets
• Broker-account labels and user-created account groups
• Lottery favorites and saved number combinations
• App preferences and feature settings
• Information voluntarily entered into text fields

Financial and trading-related information

When you voluntarily use trading or broker-related features, OES may process information such as:

• Account type and account size
• Positions, quantities and selected instruments
• Entry, current, stop and target prices
• Profit-and-loss information
• Drawdown limits and risk settings
• Broker or proprietary-trading-firm names
• Trade history and performance information

OES does not ask users to publish banking passwords, payment-card numbers or brokerage login credentials inside ordinary trade-journal fields.

Technical and diagnostic information

• Device type and operating-system version
• App version
• Internet Protocol address
• Request timestamps
• Crash reports and error logs
• Performance and reliability information
• Security and abuse-prevention signals

Website information

When you visit an OES website, the hosting provider may automatically process standard server-log information needed to deliver and secure the site.

03

How we use information

OES may use information to:

• Create and maintain user accounts
• Authenticate users and protect account access
• Provide requested website and application features
• Store watchlists, trades, favorites and preferences
• Generate analytics, calculations and personalized context
• Operate trading-risk and performance tools
• Provide prediction and pattern-analysis features
• Synchronize information across supported devices
• Respond to support and business inquiries
• Diagnose crashes, errors and performance issues
• Protect OES, its users and its systems from abuse
• Comply with legal obligations
• Develop and improve OES products

04

Trading and broker information

ChaseInGreen provides decision-support, educational, analytical, journaling and risk-awareness tools.

Unless a clearly identified execution feature is introduced in the future, ChaseInGreen does not place trades or move money on a user’s behalf.

Information entered into or received by trading features may be used to:

• Calculate risk and position impact
• Display open and closed trade information
• Compare current prices with user-defined levels
• Track drawdown and account rules
• Provide trade-management context
• Generate personal performance summaries

Users remain responsible for verifying all prices, balances, trading rules and order information with their broker or trading platform.

05

Artificial-intelligence features

Certain OES features may use automated systems, statistical analysis, machine learning or artificial intelligence to produce summaries, predictions, classifications, educational explanations or decision-support information.

Information supplied to these features may be processed to generate the requested output and to maintain the safety, reliability and performance of the service.

AI-generated content may contain errors and should not be treated as guaranteed, professional financial, legal, tax or investment advice.

06

Service providers

OES may use third-party providers to operate its services. Depending on the product and configuration, these providers may include:

• Apple services for application distribution, TestFlight, purchases and device functionality
• Authentication providers for secure account registration and login
• Render or another cloud-hosting provider for application hosting and server infrastructure
• Managed database providers for storing application data
• Email providers for support and business communication
• Market-data or broker-information providers when those integrations are enabled
• Crash-reporting, diagnostics or analytics providers when enabled

These providers may process information only as necessary to provide their services, subject to their own contractual obligations and privacy terms.

07

How information may be shared

OES does not sell personal information.

Information may be shared:

• With providers that help operate OES services
• At your direction or with your consent
• To complete a feature or integration you request
• To investigate fraud, abuse or security incidents
• To comply with applicable law or valid legal process
• To protect the rights, safety and property of OES or others
• As part of a merger, financing, acquisition, reorganization or transfer of business assets

OES does not use personal information to track users across applications or websites owned by unrelated companies for targeted advertising unless that practice is clearly introduced, disclosed and authorized as required by law and platform rules.

08

Data retention

OES retains information for only as long as reasonably necessary to provide the service, maintain legitimate business records, resolve disputes, protect security and satisfy legal obligations.

Retention periods may vary based on the type of information, the service involved and whether the user maintains an active account.

Some information may remain temporarily in backups, logs or fraud-prevention systems after an account is deleted.

09

Data security

OES uses reasonable administrative, technical and organizational measures intended to protect information from unauthorized access, loss, misuse or alteration.

These measures may include:

• Encrypted network connections
• Protected authentication processes
• Access controls
• Environment-variable and secret management
• Database access restrictions
• Logging and security monitoring
• Software updates and vulnerability remediation

No internet-connected system can guarantee absolute security. Users should protect their devices and account credentials.

10

Your privacy rights and choices

Depending on where you live, you may have the right to:

• Request access to personal information
• Request correction of inaccurate information
• Request deletion of eligible information
• Request a portable copy of certain information
• Object to or restrict certain processing
• Withdraw consent where processing depends on consent
• Appeal a privacy-request decision where required

OES may need to verify your identity before completing a privacy request.

Submit privacy requests to:

info@otisexecutionsystems.com

11

Account and data deletion

Users may request deletion of an OES account and associated eligible personal information by contacting:

info@otisexecutionsystems.com

Please use the subject line: Delete My OES Account.

The request should be sent from the email address associated with the account. OES may request additional information to verify account ownership.

Certain records may be retained when required for security, fraud prevention, legal compliance, financial reporting or dispute resolution.

12

Children’s privacy

ChaseInGreen and OES financial technology services are not directed to children under 13.

OES does not knowingly collect personal information from children under 13 through those services without appropriate authorization. If OES learns that such information was collected improperly, it will take reasonable steps to delete it.

Separate educational or youth programs may use different registration, consent and privacy procedures appropriate to those programs.

13

Changes to this policy

OES may update this Privacy Policy as products, providers, legal requirements or data practices change.

The updated policy will be posted at this URL with a revised effective date. Material changes may also be communicated through the relevant application, website or account email.