Privacy Policy
Last updated: March 2026
Praevex Ltd ("Praevex", "we", "us", or "our"), operating as TrancheBook, is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and share your personal data when you use the TrancheBook platform ("Platform").
1. Data We Collect
We collect the following categories of data:
1.1 Account Information
- Name, email address, and authentication credentials (managed by Clerk).
- Professional information provided during onboarding, including investor status and firm affiliation.
- Identity verification documents submitted for KYC compliance.
1.2 Portfolio Data
- Holdings information you upload, including fund names, commitment amounts, vintage years, and NAV data.
- Portfolio analytics and derived metrics generated by our AI engine.
1.3 Usage Data
- Pages visited, features used, and interaction patterns within the Platform.
- Search queries, company views, and analysis requests.
- Device information including browser type, operating system, and screen resolution.
- IP address and approximate geolocation (country and region level only).
1.4 AI Interaction Logs
- Queries submitted to Cole, our AI analysis engine.
- Analysis outputs generated for your account.
- Feedback you provide on AI-generated content (e.g., accuracy ratings).
2. How We Use Your Data
We use your data for the following purposes:
- Service delivery: To provide AI-generated analysis, scoring, IC packages, and portfolio insights.
- Account management: To authenticate you, manage your subscription, and communicate about your account.
- Platform improvement: To analyse usage patterns, improve AI model accuracy, and develop new features.
- Compliance: To verify identity, enforce eligibility requirements, and comply with applicable laws and regulations.
- Security: To detect and prevent fraud, abuse, and security threats.
- Communication: To send service updates, security notices, and, with your consent, marketing communications.
3. Third-Party Data Processors
We share data with the following third-party processors, each under appropriate data processing agreements:
| Processor | Purpose | Data Shared |
|---|---|---|
| Anthropic (Claude API) | AI analysis engine powering Cole | Anonymised company data, analysis prompts. No personal data or portfolio data is sent to Anthropic. |
| Stripe, Inc. | Payment processing | Name, email, payment method details. Praevex does not store card numbers. |
| Clerk | Authentication and identity management | Name, email, authentication tokens, session data. |
| Vercel | Hosting and CDN | Standard web request data (IP address, user agent). |
4. Portfolio Data Protection
We apply enhanced protections to portfolio data given its sensitive nature:
- Encryption: All portfolio data is encrypted at rest using AES-256 and in transit using TLS 1.3.
- Isolation: Portfolio data is logically isolated per user. No user can access another user's portfolio data.
- No sharing: Portfolio data is never sold, shared with third parties, or used to train AI models.
- Hard deletion: Upon request, we will permanently and irrecoverably delete all portfolio data associated with your account within 30 days.
- Access controls: Portfolio data access is restricted to automated systems. Human access requires documented justification and management approval.
5. Your Rights Under GDPR
If you are located in the European Economic Area (EEA), United Kingdom, or a jurisdiction with equivalent data protection laws, you have the following rights:
- Right of access: Request a copy of the personal data we hold about you.
- Right to rectification: Request correction of inaccurate or incomplete personal data.
- Right to erasure: Request deletion of your personal data, subject to legal retention obligations.
- Right to data portability: Request a machine-readable export of your personal data.
- Right to restrict processing: Request that we limit processing of your data in certain circumstances.
- Right to object: Object to processing based on legitimate interests, including profiling.
- Right regarding automated decisions: Request human review of significant automated decisions (see Section 6 of our Terms of Service).
To exercise any of these rights, contact us at privacy@tranchebook.com. We will respond within 30 days.
6. Data Retention
We retain personal data for the following periods:
- Account data: Retained for the duration of your account plus 12 months after closure.
- Portfolio data: Retained until you request deletion or 90 days after account closure, whichever is sooner.
- AI interaction logs: Retained for 24 months for model improvement and audit purposes, then anonymised or deleted.
- Usage analytics: Retained in anonymised, aggregated form indefinitely. Identifiable usage data is deleted after 24 months.
- KYC documentation: Retained for the period required by applicable anti-money laundering regulations (typically 5 years after the end of the business relationship).
- Payment records: Retained for 7 years as required by tax and financial regulations.
7. Cookies and Tracking
TrancheBook uses a minimal cookie policy. We use only the following cookies:
- Authentication cookies: Essential cookies required to maintain your login session. These are strictly necessary and cannot be disabled.
- Preference cookies: To remember your display preferences (e.g., theme selection). These are optional.
We do not use third-party advertising cookies, tracking pixels, or cross-site tracking technologies. We do not participate in ad networks or sell data to advertisers.
8. International Data Transfers
Your data may be processed in jurisdictions outside your country of residence, including the United States (where our infrastructure providers operate). Where data is transferred outside the EEA or UK, we ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the European Commission.
9. Children's Privacy
The Platform is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has provided us with personal data, please contact us and we will promptly delete such data.
10. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be communicated via email or prominent notice on the Platform at least 30 days before they take effect. The "Last updated" date at the top of this page reflects the most recent revision.
11. Contact Us
For questions about this Privacy Policy or to exercise your data protection rights, contact us at:
Praevex Ltd (trading as TrancheBook)
Email: privacy@tranchebook.com