DRAFT — REQUIRES ATTORNEY REVIEW BEFORE PUBLISHING. Not legal advice.

Privacy Policy

NINJABOT-AI — Privacy Policy
Effective Date: [PLACEHOLDER — effective date]

This Privacy Policy explains how BAA Group (3741 SW 133rd Pl, Miami, FL 33175, United States), doing business as NINJABOT-AI ("we," "us," "our"), collects, uses, shares, and protects information when you visit our website, create an account, or purchase a subscription (collectively, the "Service"). This policy should be read together with our Cookie Policy.

1. Scope

This policy applies to visitors, account holders, and subscribers of the NINJABOT-AI website and Software. It does not apply to third-party sites or platforms we link to or interoperate with (including NinjaTrader or any broker/evaluation firm's own site), which have their own privacy practices.

2. Information We Collect

a. Information you provide directly: name, email address, billing/shipping details collected at checkout, account login credentials, support/contact-form messages, and any information submitted through our Contact page for the custom/Lifetime tier.

b. Payment information: Payment card details are collected and processed directly by Shopify Payments and our subscription-billing provider. We do not store full payment card numbers on our own servers.

c. License and usage data: license/activation key status, software version, update history, and basic usage metadata needed to deliver, gate, and revoke access to the Software.

d. Automatically collected / technical data: IP address, browser type, device information, pages viewed, referring URLs, and similar data collected via cookies, pixels, and similar technologies, including the Meta Pixel. Categories of cookies and your choices are described in our separate Cookie Policy.

3. How We Use Information

We use the information described above to: create and manage your account; process payments and manage subscriptions; deliver, activate, and revoke license/activation access; provide customer support; send transactional communications (e.g., billing receipts, renewal notices, access changes); operate and improve the Service and website; measure and run advertising, including Meta/Facebook ads; and comply with legal, tax, and payment-processor obligations.

We do not use any information collected through the Service to provide individualized investment advice, and account/usage data is not used to generate personalized trading recommendations.

4. Cookies and Tracking Technologies

We and our service providers use cookies, pixels (including the Meta Pixel), and similar technologies for site functionality, analytics, and advertising measurement. Where required, a cookie-consent banner lets you choose non-essential categories. Full detail on cookie categories, purposes, and opt-out choices is provided in our separate Cookie Policy, linked in the site footer.

5. Third-Party Service Providers

We share information with service providers who process it on our behalf, including:

• Shopify / Shopify Payments — e-commerce platform and payment processing;
• Shopify Subscriptions — recurring billing and customer billing-portal management;
• Email/communications provider — transactional and account-related email;
• Meta (Facebook/Instagram) — advertising delivery and measurement via the Meta Pixel, subject to Meta's Financial Products and Services advertising requirements; and
• Analytics providers — aggregate site-usage analytics.

These providers are authorized to use your information only as necessary to provide their services to us and are bound by their own data-processing terms.

6. Advertising Disclosure

Because NINJABOT-AI advertises financial-adjacent software on Meta platforms, our ads run under Meta's mandatory Financial Products and Services Special Ad Category, with completed advertiser identity verification. The Meta Pixel installed on our site shares certain browsing/conversion data with Meta for ad measurement and targeting, subject to your cookie choices and Meta's own data practices. You can manage ad personalization through your Meta account settings and through our cookie-consent tool.

7. Data Sharing and Disclosure

We do not sell your personal information. We disclose information only: to the service providers listed above; when required by law, regulation, or valid legal process (including requests from payment processors or regulators); to protect our rights, property, or safety, or that of our users; or in connection with a merger, acquisition, or sale of assets, subject to continued confidentiality obligations.

8. Data Retention

We retain account, billing, and license data for as long as your account is active and for a period thereafter as needed to comply with tax, accounting, payment-dispute, and legal obligations, after which it is deleted or anonymized. 7 years for billing and tax records — confirm with accountant/counsel.

9. Your Rights and Choices

Depending on your jurisdiction, you may have rights to access, correct, export, or delete your personal information, and to object to or restrict certain processing (for example, under GDPR for EU/UK residents or CCPA/CPRA for California residents). To exercise these rights, contact us at support@ninjabot-ai.com. We will verify your identity before acting on a request. [PLACEHOLDER — counsel to confirm jurisdiction-specific rights language and any required regulator contact info before publishing.]

10. Data Security

We use commercially reasonable technical and organizational measures to protect information, including relying on Shopify Payments' PCI-compliant infrastructure for payment data. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

11. Children's Privacy

The Service is not directed to, and we do not knowingly collect personal information from, individuals under 18. If we learn we have collected such information, we will delete it.

12. International Data Transfers

If you access the Service from outside the United States, your information may be transferred to and processed in that country or other countries where our service providers operate, which may have different data-protection laws than your own. [PLACEHOLDER — counsel to confirm transfer-mechanism language, e.g., SCCs, if EU/UK users are expected.]

13. Changes to this Policy

We may update this Privacy Policy from time to time. Material changes will be posted on this page with a new effective date. Continued use of the Service after changes take effect constitutes acceptance.

14. Contact Us

Questions about this Privacy Policy or your data: support@ninjabot-ai.com.