Privacy notice

1. Information collected

1.1 Information you provide

When you create an account or use the Service, we may collect the following categories of information:

• Identity details: your given name, family name and date of birth.
• Contact details: your email, telephone number and residential address.
• Financial details: Broker API credentials limited to reading and executing orders, along with your investment preferences and risk controls. We do not store full broker passwords or payment-card numbers.
• Profile details: your username, strategy settings and notification preferences.
• Communications: messages sent through support channels or by email.

1.2 Automatically collected information

When you use the Service, certain technical information is collected automatically:

• IP address, browser type and version, and operating system.
• Pages visited, features used, time spent and clickstream data.
• Device identifiers and, where applicable, mobile advertising identifiers.
• Cookie and tracking-tool information (see our Cookie Notice).

1.3 Information received from third parties

Information may come from identity-verification providers, fraud-prevention services and analytics partners. We may combine it with information already held to improve accuracy and protect the Service.

2. Uses of information

We may use collected information to:

• Create, manage and provide your account and the Service.
• Process trading signals and automated orders through linked brokers.
• Personalise your experience and present relevant market information.
• Deliver service communications, including confirmations, trading notices and security alerts.
• Send marketing communications where you have opted in or applicable law permits.
• Detect, investigate and prevent fraud or unlawful conduct.
• Comply with legal and regulatory obligations.
• Develop, test and improve the Service using aggregated and anonymised data.

3. Legal bases for processing (EEA and UK users)

For individuals in the European Economic Area or the United Kingdom, we process personal data on the following legal bases:

• Performance of a contract: to provide the Service you request when opening an account.
• Legitimate interests: preventing fraud, maintaining security and improving the product.
• Legal obligation: meeting financial-law and tax requirements.
• Consent: for marketing and optional cookies, which you may withdraw at any time.

4. Disclosure of information

We do not sell personal data. We may share it with:

• Service providers: cloud hosting, email, analytics and support suppliers that are contractually required to protect your information.
• Linked brokers and exchanges: only the API instructions necessary to execute the strategy you have configured.
• Authorities: when required by law, court order or to protect our legal rights.
• Corporate transactions: in connection with a merger, acquisition or transfer of assets, provided the recipient continues to follow this policy.

5. International data transfers

Trading Elevate offers services across international markets. Your information may be transferred to and handled in countries beyond your residence, including the United States and EU Member States. Where required, we use Standard Contractual Clauses approved by the European Commission for international transfers.

6. Data retention

We retain personal data while your account is active or for as long as necessary to provide the Service. After closure, certain information may be kept for up to seven years to satisfy financial-regulatory obligations. Aggregated and anonymised analytics may be retained indefinitely.

7. Your data rights

Depending on where you live and the law that applies, you may have the right to:

• Request a copy of the personal information we hold about you.
• Ask us to correct inaccurate or incomplete information.
• Ask us to remove your personal information, also known as the “right to be forgotten”.
• Challenge specific processing activities or request that we restrict them.
• Ask to receive your data in a structured format that can be read by machines.
• Revoke your consent whenever you choose, without changing the lawfulness of earlier processing.

To submit a data-rights request, please contact us at [email protected]. We normally respond within 30 days.

8. Protecting your information

We use measures including TLS 1.3 for information in transit, AES-256 encryption for stored information, multi-factor authentication, access based on roles and annual independent penetration tests. Absolute security cannot be promised. Choose a strong password that you do not reuse and enable two-factor authentication.

9. Use of cookies

Cookies and similar tools support the operation and improvement of the Service. More detail can be found in our Cookie Policy.

10. Children’s privacy

The Service is for individuals aged 18 and above. We do not knowingly collect children’s personal data. If you believe a child has sent us information, please notify us so we can delete it without undue delay.

11. Changes to this policy

We may revise this Privacy Policy from time to time. Material amendments will be announced on the website or sent by email. Using the Service after the revised version becomes effective indicates acceptance of the changes.

12. Contact details

For privacy enquiries or to exercise your rights, please contact our Data Protection Officer:

• Email: [email protected]
• Postal address: Trading Elevate Inc. 200 Park Avenue, New York, NY 10166, United States, United States
• EU representative: Trading Elevate, 200 Park Avenue, New York, NY 10166, United States