Privacy Policy

MarketLogAI — Terms of Service & Privacy Policy, Part II

Last Updated: October 18, 2026

This Privacy Policy explains how Juan Jorge Alvarez, operating as MarketLogAI, collects, uses, processes, stores, and discloses information through our advertising optimization Services.

1. Who We Are

Juan Jorge Alvarez is the business providing the Services directly to you.

Business Address: 652 W 189th St, NY, NY 10040

Privacy Contact: [email protected]

We use independent technology providers, including Halcrus and its current and future operating entities, to deliver our Services.

Depending on the processing activity and applicable law, we may act as a data controller or business, while our technology providers may act as processors or service providers.

Actual responsibilities depend on the processing relationship and applicable law.

2. Information We Collect

We may collect:

• Account Information: Names, email addresses, business information, contact details, and account registration information.
• Advertising Information: Connected advertising account identifiers, campaign information, advertising budgets, expenditure, performance metrics, campaign statuses, and optimization records.
• Payment Information: Billing details, transaction records, payment status, and limited payment-method information received from payment processors.
• Technical Information: IP addresses, browser information, device information, access records, application logs, and security-related information.
• Communications: Information submitted through customer support, inquiries, and other communications.

3. How We Use Information

We process information as necessary and legally permitted to:

• Provide and operate our Services.
• Authenticate and manage accounts.
• Connect authorized advertising accounts.
• Analyze advertising performance.
• Execute authorized automated optimization actions.
• Calculate applicable fees.
• Process payments and subscriptions.
• Maintain billing and action records.
• Provide customer support.
• Investigate errors and disputes.
• Detect fraud and unauthorized activity.
• Maintain service security and reliability.
• Comply with legal obligations.

Where required by applicable law, our processing relies on an appropriate legal basis, such as performance of a contract, legitimate interests, compliance with legal obligations, or consent.

4. Advertising Platform Data

Our Services connect to advertising platforms, including Meta, through authorized integrations.

We may process advertising account information necessary to analyze performance and perform authorized optimization actions.

This may include campaign names, identifiers, budgets, advertising expenditure, performance metrics, and related operational information.

We process advertising platform information subject to applicable platform terms, permissions, and privacy laws.

We do not acquire ownership of advertising platform information merely by accessing or processing it.

5. Underlying Technology Providers

Our Services use technology and infrastructure supplied by third-party providers.

These include Halcrus and its current and future operating entities, including but not limited to SuperX Labs LLC, together with authorized affiliates, contractors, and infrastructure providers.

These providers may process authorized advertising information and related operational data to deliver the Services.

Changes to the corporate structure of an underlying technology provider do not automatically change our role as your customer-facing service provider.

Where required by applicable law, we will provide notices regarding material changes to data processing or responsible entities.

6. Artificial Intelligence Processing

Our Services use AI-powered functionality to analyze advertising information and support automated optimization.

We use OpenAI's API through an API account maintained by our business.

Authorized information may be transmitted to OpenAI to perform relevant analysis.

This information may include campaign names, identifiers, budgets, advertising expenditure, performance metrics, and account statuses.

OpenAI's handling of information is governed by its applicable agreements, policies, and the configuration of our API account.

OpenAI states that API inputs and outputs are not used to train its models by default unless the API customer affirmatively opts into applicable data-sharing arrangements.

We are responsible for maintaining appropriate account configurations, permissions, and legally required disclosures concerning our use of AI services.

7. Payment Processing

Payments are processed through Stripe or another payment provider identified during checkout.

We act as the merchant of record for our customer transactions, subject to the applicable payment arrangement and payment processor requirements.

Payment processors may independently collect and process information necessary to authorize transactions, prevent fraud, and comply with legal obligations.

Their processing may be subject to separate privacy policies and contractual terms.

8. Information Sharing

We may disclose information to service providers that assist with operating our Services.

These may include:

• Halcrus and its operating entities: Underlying advertising optimization technology.
• Meta: Advertising account connectivity and authorized operations.
• OpenAI: AI-assisted analysis.
• Stripe: Payment processing.
• Authorized third-party service providers: Hosting, security, communications, and other operational services.

We may also disclose information where legally required, to investigate security incidents, to enforce legal rights, or in connection with legitimate business transactions.

We do not sell personal information for monetary consideration.

We do not share personal information for cross-context behavioral advertising or engage in activities that constitute a ‘sale’ or ‘sharing’ under applicable privacy laws.

9. Data Retention

We retain information for as long as reasonably necessary to provide Services, maintain security, satisfy legal obligations, and resolve legitimate disputes.

Our retention practices: Account and advertising data are retained for the duration of your active subscription plus 90 days, while billing and tax records are retained for 7 years.

Information may be retained for accounting, tax, billing, fraud prevention, security, and legal purposes where appropriate.

We delete or de-identify information when no longer required, subject to applicable legal obligations and third-party platform requirements.

10. Data Security

We implement reasonable technical, administrative, and organizational safeguards designed to protect information against unauthorized access, loss, misuse, or disclosure.

Our technology providers may implement additional safeguards within their respective systems.

No internet-connected system can be guaranteed completely secure.

Where required by applicable law, we will provide notifications regarding qualifying security incidents.

11. International Data Processing

Information may be processed in jurisdictions where we or our authorized service providers operate.

These may include the United States and other countries.

Where applicable law requires safeguards for international transfers, we will implement appropriate transfer mechanisms or other legally recognized safeguards.

12. Your Privacy Rights

Depending on applicable law, you may have rights to access, correct, delete, export, or restrict processing of personal information.

You may also have rights to object to certain processing activities or withdraw consent where processing relies on consent.

Requests may be submitted to [email protected].

We may verify your identity or authority before fulfilling requests.

Where another organization is responsible for determining the purposes and means of processing, we may refer requests to that organization or assist it as legally required.

13. Children

Our Services are intended for business users aged 18 or older.

We do not knowingly collect personal information from children.

14. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our Services, processing practices, or legal obligations.

Material changes will be communicated as required by applicable law.

We will not rely on retroactive changes to authorize materially different uses of previously collected information where additional notice or consent is legally required.

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