DVPV Holdings, LLC ("DVPV Holdings," "we," "us," or "our") operates dvpvholdings.com
and owns and operates Headless Alpha (headlessalpha.com). This Privacy Policy explains
how we collect, use, disclose, and protect information about you when you use our websites
or any of our software products and services (collectively, the "Services").
By accessing or using our Services, you agree to this Privacy Policy. If you do not
agree, please do not use our Services.
1. Information We Collect
1.1 Information You Provide Directly
We collect information you provide when you:
- Create an account (name, email address, password)
- Complete a purchase or subscribe to a plan (billing details processed by Stripe — we do not store card numbers)
- Submit a contact or inquiry form (name, email, message content)
- Connect a brokerage account (API keys stored encrypted in Google Cloud Secret Manager)
- Configure alert sources, trading rules, or strategy settings
1.2 Information Collected Automatically
When you use our Services, we may automatically collect:
- Log data (IP address, browser type, pages visited, timestamps)
- Device information (operating system, browser version)
- Usage data (features used, clicks, session duration)
- Firebase Analytics data (aggregated, anonymized)
1.3 Trading and Financial Data
For users of Headless Alpha, we collect and process:
- Alert signals and trade instructions you or your chosen alert publishers send to the platform
- Order execution records and brokerage transaction data retrieved via API
- Agent event logs (decisions, AI reasoning outputs, order statuses)
We do not provide investment advice. All trading activity is executed
pursuant to your own strategies and configurations.
2. How We Use Your Information
We use collected information to:
- Provide, operate, and improve our Services
- Process payments and manage subscriptions via Stripe
- Execute and monitor automated trading orders on your behalf through your connected brokerage
- Send you transactional emails (trade notifications, HITL approval requests, billing receipts)
- Detect and prevent fraud, abuse, and security incidents
- Comply with applicable laws and regulations
- Respond to your support requests and inquiries
We do not sell your personal information to third parties. We do not
use your financial data for any purpose beyond operating the Services you have subscribed to.
3. How We Share Your Information
We may share information with:
- Stripe: Payment processing. Stripe's use of your information is governed by Stripe's Privacy Policy.
- Google Cloud Platform: Infrastructure hosting (Cloud Run, Cloud SQL, Secret Manager, Firebase). Your data is stored in Google Cloud.
- SendGrid: Transactional email delivery.
- Your connected brokerage: We send order instructions to your brokerage (e.g., Alpaca) via their API using credentials you provide.
- Law enforcement or regulators: When required by applicable law, court order, or regulatory obligation.
4. Data Retention
We retain your personal data for as long as your account is active or as needed to
provide Services. Agent event logs and trade records are retained for a period determined
by your subscription plan (30 days for Starter, 12 months for Pro, unlimited for Elite).
After account deletion, we may retain anonymized aggregate data and records required for
legal or regulatory compliance for up to 7 years.
5. Security
We implement industry-standard security measures including:
- HTTPS/TLS encryption in transit
- Brokerage API keys stored in Google Cloud Secret Manager (never in plaintext)
- Firebase App Check to prevent unauthorized API access
- Role-based access controls on all internal systems
- Two-factor authentication (2FA) available and encouraged for all accounts
No method of transmission or storage is 100% secure. If you discover a security
vulnerability, please report it to security@dvpvholdings.com.
6. Your Rights
Depending on your jurisdiction, you may have the right to:
- Access the personal data we hold about you
- Request correction of inaccurate data
- Request deletion of your account and associated data
- Opt out of non-essential communications
- Data portability (export of your trade records)
To exercise these rights, contact us at privacy@dvpvholdings.com.
7. Cookies
Our websites use essential cookies for authentication and session management (Firebase
Auth). We do not use third-party advertising or tracking cookies. You may disable cookies
in your browser settings, but doing so may prevent you from logging in or using certain
features.
8. Children's Privacy
Our Services are not directed to individuals under the age of 18. We do not knowingly
collect personal information from minors. If you believe we have inadvertently collected
such information, contact us at privacy@dvpvholdings.com
and we will delete it promptly.
9. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material
changes by posting the new policy on this page and updating the "Last Updated" date above.
Continued use of the Services after changes constitutes acceptance of the revised policy.
10. Contact Us
If you have questions about this Privacy Policy, contact us at: