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Privacy Policy

Last Updated: September 4, 2026

1. Introduction

STRATIFLUX COMPANY LIMITED ("Stratiflux", "Company", "we", "our", "us") operates stratiflux.com, the Academy portals, in-browser labs, and paid tools available through stratiflux.com and mololuwa.com (collectively, the "Service"). StratiSell is a separate product with its own notice at stratisell.com/privacy.

This policy is governed by the Nigeria Data Protection Act 2023 (NDPA) and the General Application and Implementation Directive (GAID) 2025. The General Data Protection Regulation (GDPR) also applies where we process personal data of EU/EEA residents.

Data controller: STRATIFLUX COMPANY LIMITED (RC 8282887), Plot 182, 44 Crescent, CITEC Villas, Victoria Court, Gwarinpa Estate, Abuja, FCT, Nigeria.

Data Protection Officer: Emmanuel Adeleke. [email protected]

Supervisory authority (Nigeria): Nigeria Data Protection Commission (NDPC), ndpc.gov.ng.

2. Information We Collect

Depending on how you use the Service, we may collect the following categories:

  • Account and identity data: Name and email address when you register for a portal or tool account.
  • AI chat and Lab Copilot data: Prompts, replies, and sandbox command/exit-code context needed to coach or answer you.
  • Payment data: For paid tools, the payment provider collects card details. We receive payment status, amount, and a provider reference, not your full card number.
  • Wealth Studio data: Portfolio names, starting amounts, investments, trade history, notes, performance snapshots, notification settings, generated portfolio briefs that you choose to save, and the Full Net Worth details you add, including holdings, cash, property or business values, income and monthly costs. The server stores financial record contents as application-encrypted data and uses a pseudonymous owner identifier instead of your email as the record key.
  • Documents and recordings you upload to add details: A screenshot, photo, PDF, spreadsheet, CSV, typed text, or a voice recording you choose to send. These are read once to pull out the amounts, held in memory for that request only, and never written to our storage. Only the rows you confirm on screen are saved, as Wealth Studio data.
  • Market research requests: Symbols, timeframes, and questions you submit to Market Intelligence. These requests are processed to return the analysis and are not added to your saved portfolio record.
  • Newsletter: Email address if you subscribe.
  • Event RSVP data: Name, email, phone, and dietary notes you submit for events.
  • Usage and technical data: IP address, browser or device characteristics, timestamps, and standard server logs.

3. Lawful Basis (NDPA and, where applicable, GDPR)

We process personal data on the following bases:

  • Contract: Creating and managing your account, delivering labs, portals, and paid tools you request.
  • Consent: Newsletter sends, optional analytics cookies, and AI chat you choose to use.
  • Legitimate interests: Security, fraud prevention, and keeping the Service reliable, balanced against your rights.
  • Legal obligation: Tax, accounting, and regulator requests under Nigerian law.

Where we rely on consent, you may withdraw it at any time without affecting processing that already happened. Withdrawal does not delete records we must keep for tax or dispute purposes.

4. How We Use Your Information

We use personal data to:

  • Provide, operate, and maintain the Service and your account.
  • Process AI chat and Lab Copilot requests. OpenAI generates replies through Stratiflux's API account. We do not use those chats to train a public Stratiflux model.
  • Calculate portfolio views, risk measures, exports, and alerts you request. If you run a portfolio brief, we send the selected symbols and relative measures such as weights and percentage returns to OpenAI for that request. We do not send your portfolio name, email address, share count, total value, or cash amount in that prompt.
  • Read a document, image or recording you upload so its amounts can be turned into rows you review. The file or recording is sent to OpenAI for that single request and is not stored by us. We do not send your email address or your existing saved amounts with it; the names of your existing rows are sent so a spoken correction can be matched to the right one.
  • Take payment for paid tools through Paystack (NGN) or Flutterwave (USD/EUR) where those tools are enabled.
  • Send transactional messages and, where you subscribed, newsletter emails.
  • Manage event registrations.
  • Monitor security, enforce our terms, and comply with legal obligations.

We do not sell your personal data. We share data only as described here or when required by law.

5. Third-Party Processors

We use service providers who process personal data on our instructions:

  • OpenAI (United States): AI chat, Lab Copilot, Market Intelligence, user-requested portfolio brief inference, reading documents and images you upload, and transcribing voice notes you record.
  • Postmark (United States): transactional and newsletter email.
  • PostHog (European Union / configured region): product analytics only after you choose Accept all on the cookie banner.
  • Paystack (Nigeria) and Flutterwave (Nigeria / Global): paid-tool checkout.
  • Cloudflare (global edge): CDN, TLS, and bot protection.
  • Oracle Cloud Infrastructure and Google Cloud Platform: hosting in the regions we configure.

We may also disclose information if required by law, regulation, or to protect the rights, safety, or property of Stratiflux, our users, or others.

6. International Data Transfers

Some processors (OpenAI, Postmark, OCI, Cloudflare) handle data outside Nigeria, including the United States. Under NDPA Part VIII we document a transfer ground for each route and review it with a qualified adviser. A foreign contractual clause is not an NDPC approval. For EU/EEA data we also use Standard Contractual Clauses where required.

7. Data Retention

We retain personal data only as long as necessary for the purposes described:

  • Account data: While your account is active. After a verified deletion request we delete eligible account data within thirty (30) days unless a longer period is required by law.
  • AI chat history: Ninety (90) days, then purged unless a legal hold applies.
  • Wealth Studio portfolio and net worth records: Until you erase them in the product or close the service. The Erase all control removes eligible server-stored portfolio and net worth records immediately from the active database. Encrypted backup copies age out under the backup retention schedule, unless a legal hold applies.
  • Uploaded documents and voice recordings: Not retained. They exist for the length of the request that reads them.
  • Private sign-in data: One-time sign-in and purchase-restoration code records expire after ten (10) minutes. A trusted-device session expires after thirty (30) days or when you sign out.
  • Newsletter: Until you unsubscribe or we end the list.
  • Payment records: At least seven (7) years where Nigerian tax and accounting rules require it.

To request deletion or other rights, email [email protected].

8. Your Rights and SNAG

Under the NDPA 2023 and, where applicable, the GDPR, you may request access, correction, erasure, restriction, portability, objection, withdrawal of consent, and human review of a solely automated decision that materially affects you. You may lodge a complaint with the NDPC or your local authority.

Email [email protected] with the subject "Data Privacy Complaint" for the Standard Notice to Address Grievance (SNAG) path. We acknowledge within 7 business days and respond substantively within 30 days of a verifiable request.

9. Cookies

Essential cookies keep you signed in (for example the portal session cookie). Wealth Studio uses a separate essential private-session cookie after email-code verification. It expires after thirty (30) days and does not contain your email or financial records. Analytics cookies (PostHog) load only if you choose Accept all. Necessary only leaves analytics off. We do not currently load advertising pixels on this site. You can change your choice by clearing site data for stratiflux.com, which shows the banner again.

10. Security of Your Information

We implement technical and organizational measures designed to protect personal data. Wealth Studio financial record contents use authenticated AES-256-GCM application encryption before database storage. Database owner keys are pseudonymous keyed hashes. Encryption keys are held separately in managed secret storage. Connections use encryption in transit where appropriate, access is restricted, and recovery controls are tested. Full Net Worth details are held the same way once you have verified your email for a private session, and a browser copy is kept for the current tab, or for the device if you choose Remember on this device. No method of transmission or storage is completely secure.

11. Children's Privacy

The Service is not directed at individuals under 18. We do not knowingly collect personal information from children. If you believe we have, contact [email protected] and we will delete it.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post the revised version on this page and update the Last Updated date above. Material changes may be communicated through the Service or by email where required by law.

13. Contact Us

For questions about this policy or to exercise your rights:

Email: [email protected]