Privacy Policy

1. Data Controller

The data controller responsible for your personal data is:

2. What Personal Data We Collect

The broker-derived items above describe what we would hold if a brokerage connection were available. It is not: the Service offers no live broker connection today (section 5.2), so we currently hold no broker tokens, orders, fills, or positions for anyone. Paper-trading records are simulated and are generated inside the Service.

3. Sources of Personal Data

4. Why We Process Your Data and on What Legal Basis

For California consumers, the equivalent CCPA "business purposes" are: providing the Service, security and fraud prevention, debugging, internal research, quality and safety maintenance, and complying with law.

For Israeli users, processing is conducted in accordance with the Israeli Protection of Privacy Law and the Privacy Protection Regulations (Information Security), 5777-2017.

5. How We Share Your Data

We share personal data only in the limited circumstances below, and only with parties bound by appropriate contractual and security commitments.

If we are involved in a merger, acquisition, financing, reorganization, or sale of assets, personal data may be transferred to the successor entity. We will notify you of any such transfer and any change in privacy practices.

For any other sharing not described above.

6. International Data Transfers

Adequacy decisions — for example, the European Commission has recognized Israel as providing an adequate level of protection (Decision 2011/61/EU, renewed 2024).

Standard Contractual Clauses (SCCs) — Module 2 (controller-to-processor) or Module 3 (processor-to-processor) per Implementing Decision (EU) 2021/914.

EU-U.S. Data Privacy Framework participation by U.S. service providers where applicable.

UK International Data Transfer Addendum for transfers from the UK.

Supplementary measures including encryption in transit and at rest, pseudonymization, and access controls.

7. Retention

We retain personal data only as long as necessary for the purposes described, or as required by law. Default retention periods:

Where law requires longer retention (e.g. court orders, ongoing investigations), the relevant data is retained until the obligation lapses.

Deleting your account is two events at two different times, and they are different facts. The product treats them as different facts, and so does this Policy.

Erasure is not one action. Every table that can hold data about you carries a written decision, and that record is the same artefact as the program the erasure runs — so what follows cannot drift from what the code does. There are three outcomes.

One identifier is replaced rather than removed. If you redeemed a free trial, the email address recorded against that redemption is overwritten with a one-way keyed value of itself, and the IP address stored beside it is deleted. The result cannot be read back, cannot be used to contact you, and is only ever compared for equality. It exists so that deleting an account and signing up again does not reopen a free trial that has already been used.

That is the complete list. We do not keep your account, your profile, your trading data, or your educational records for seven years, or for any other period, after erasure — and no tax or financial-record obligation requires us to. We hold no invoice, receipt, or payment record of our own: those are issued and held by our payment processor, Grow Payments Ltd. (Meshulam), which keeps them for its own statutory period as a controller of that data (section 5.1). We never receive your card number (section 2.5).

Erasure is applied to the live systems. Backups roll on a 30-day cycle, so an erased account leaves the backup set within 30 days of the erasure.

8. Your Privacy Rights

Deleting your account from inside the Service asks you to prove it is you a second time immediately beforehand — by re-entering your password, or by using a passkey you enrolled earlier. If you created your account with Sign in with Google and have never set a password, there is nothing for that check to verify: you have no password, and enrolling a passkey requires passing the same check. For you, the in-Service deletion will not complete.

Two routes are open, and both end in the erasure described in section 7.2:

Access (Art. 15) — obtain confirmation of processing and a copy of your data

Rectification (Art. 16) — correct inaccurate or incomplete data

Erasure "right to be forgotten" (Art. 17) — delete your data. Sections 7.1 and 7.2 set out exactly what is deleted, what is kept with your name removed, and the four records that survive erasure with the basis asserted for each

Object (Art. 21) — object to processing based on legitimate interest, including profiling and direct marketing

Withdraw consent at any time (Art. 7(3))

Lodge a complaint with your supervisory authority (see section 14)

Right to file a complaint with the Privacy Protection Authority (PPA) within the Ministry of Justice — gov.il

Set a password first. The Forgot password? link on the sign-in screen works for accounts created with Google — it emails a code to the same address. Once the account has a password, you can delete it yourself.

9. Security

No system is perfectly secure; we cannot guarantee absolute security but commit to industry best practice and continuous improvement.

Transport security — TLS 1.3 with HSTS preload; HTTP/3 where supported

Encryption at rest — AES-256 for databases and backups; provider-managed key rotation

Password storage — Argon2id or bcrypt (cost factor ≥ 12); salted; never reversible

Two-factor authentication — available for all accounts; required for staff accessing production

Broker tokens — encrypted with a customer-scoped key; access tokens kept in volatile memory where possible

Access controls — role-based (RBAC), principle of least privilege, audited quarterly

Network segmentation — private subnets for data tier; bastion-only SSH access

Vulnerability management — automated dependency scanning; SAST and DAST in CI; quarterly penetration tests

Incident response — documented runbook; 72-hour data-breach notification process aligned with GDPR Art. 33-34

10. Automated Decision-Making and AI

The Service uses AI only in advisory ways that do not determine your access:

If we ever introduce automated decision-making that affects you legally or significantly, we will obtain your explicit consent or rely on another GDPR Art. 22(2) exception, will inform you in advance, and will provide the right to obtain human intervention, express your point of view, and contest the decision.

11. Cookies and Tracking Technologies

We use cookies and similar technologies to operate, secure, and improve the Service.

We honor browser-level Global Privacy Control (GPC) signals from California residents as a valid opt-out of sale or sharing.

We log IP addresses, user-agent strings, and request paths for security and operational purposes. Logs are retained for 90 days.

12. Third-Party Links

The Service may link to third-party websites and services. Their privacy practices are their own; we are not responsible for them. Read their privacy policies before sharing personal data.

13. Changes to This Policy

14. Supervisory Authorities

You may lodge a complaint with the supervisory authority for your jurisdiction:

EU member states — your national data protection authority. List: edpb.europa.eu

United Kingdom — Information Commissioner's Office (ICO): ico.org.uk

Israel — Privacy Protection Authority (PPA): gov.il

California — CPPA: cppa.ca.gov; California Attorney General: oag.ca.gov

Federal Trade Commission (FTC) — for COPPA and other federal privacy law: ftc.gov

15. Whether Provision of Data is Required

Account registration data (email, password) is required to create an account. Without it we cannot provide the Service to you.

Billing data is required to charge subscriptions; without it you cannot purchase paid plans.

KYC verification metadata (when you connect a brokerage account) is required by your broker for legal compliance with anti-money-laundering laws; refusing to provide it means you cannot connect that broker.

Marketing-list data is purely optional. Choosing not to consent has no effect on your access to the Service.

Profile data beyond email (display name, avatar, bio) is optional; you can use the Service without it.

Cookies categorized as Functional / Analytics / Marketing are optional; the Service will operate without them, with reduced personalization.

16. Contact

We welcome questions, requests, and feedback about this Policy.