INITIATIVE / quantitative software engineering
Discuss a build
Legal

Privacy Policy

Last updated: September 2026

Who we are (the data controller)

The data controller is The 1.21 Initiative Ltd, a private limited company registered in England and Wales, company number 16726981 ("we", "us"). You can reach us at contact@121initiative.com. We are not a registered investment adviser, broker-dealer, or fund.

What we collect and why

  • Contact details you give us — if you email us, book a session, or use the contact form, we receive your name, email address, and whatever you choose to tell us. We use it to respond. Lawful basis: our legitimate interest in answering enquiries (Article 6(1)(f) UK GDPR).
  • Institutional access requests — the gated form collects your name, work email, firm, role, institution type, capital band, scope of interest, and your message. Used solely to run the qualification review and, where granted, the access relationship. Lawful basis: legitimate interest in qualifying institutional and B2B counterparties; for allocated/NDA arrangements, steps to enter a contract.
  • MCP developer signup — the /mcp/ signup collects your name, work email, optional firm, and what you're building, and issues you an access token. We use this to run the service, send your token, meter usage, and (only with your opt-in) send product updates. Lawful basis: performance of the service / legitimate interest; marketing only with consent (Article 6(1)(a)).
  • MCP token usage — token documents record email, name, firm, IP address, request timestamps, call counts, credit balances, and Stripe identifiers. This is operational data needed to deliver and meter the service and to prevent abuse. Lawful basis: contract performance and legitimate interest in running a secure, metered service.
  • Shadow Tournament submissions — when you call tournament.submit we receive the genome parameter vector you chose to submit, its hash, and your contribution choice, linked to your token. Without contribution the vector is deleted once scored and only the hash, statistics, outcome and rating are kept. With contribution the vector and outcome are retained under the licence in our Terms. Leaderboard entries show anonymised hash prefixes only. Hosted compute usage is recorded per tool as aggregate counts. Lawful basis: contract performance.
  • Payments — payments for credit packs are processed by Stripe. We never see or store your card details. We receive from Stripe your customer identifier and payment status. Lawful basis: contract performance.
  • Analytics — we use Google Analytics to understand how the site is used (pages visited, approximate region, device type), with your consent via the cookie banner. Lawful basis: consent (Article 6(1)(a)).
  • Scheduling — bookings are handled by Calendly, which has its own privacy policy.

Processors we use

Where processors transfer data outside the UK/EEA (e.g. Stripe and Google in the US), we rely on their standard contractual clauses and, where applicable, the UK Addendum.

What we don't do

  • We do not sell or share your personal data with third parties for marketing.
  • We do not send marketing email unless you've explicitly asked for it (and you can unsubscribe anytime).
  • We do not store payment information on this site.
  • Our MCP tools do not upload your orders, feature manifests, symbols, bars, or genomes to us — those stay local to your machine. The single exception is the genome vector you explicitly pass to tournament.submit, handled as described above.

Retention

We keep correspondence as long as needed to serve you and meet legal obligations. Access-request and token records (which hold name, email, firm, role, IP) are kept for the life of the token relationship plus a reasonable period afterward for abuse prevention and accounting, and are deleted on request where we are not required to keep them. Payment records are retained per tax law (typically six years).

Your rights

Under UK GDPR you have the right to access, rectify, erase, restrict, and port your personal data, and to object to processing. Email us and we'll act promptly and free of charge. You may also complain to the Information Commissioner's Office (ico.org.uk).

Cookies

We use a small consent banner before analytics cookies load. With your consent, Google Analytics sets cookies to measure site usage. You can change your choice or clear cookies in your browser at any time; the site works without them. Strictly necessary cookies (if any) are not subject to consent.

Changes

If this policy changes materially we'll update this page and the date above.