Privacy Policy

1. Information We Collect

1.1 Information You Provide

When you sign up or interact with the Service, we may collect:

• Identity Details: full legal name and date of birth.
• Contact Information: email, phone number, residential address.
• Financial Information: broker API keys (read-only or trade execution access), investment preferences, and risk tolerance. We never store your complete broker login credentials or payment card details.
• User Profile: chosen username, trading strategy preferences, notification settings.
• Communications: correspondence via support channels or email.

1.2 Data Collected Automatically

While you use the Service, we automatically gather certain technical data, such as:

• Your IP address, browser version, and operating system.
• Pages you access, features used, session length, and click paths.
• Device identifiers and mobile advertising IDs where relevant.
• Information from cookies and similar trackers (see our Cookie Policy).

1.3 Third-Party Data Sources

We may receive data from external providers like identity verification, fraud prevention, and analytics services. This information is combined with our records to improve accuracy and security.

2. How We Use Your Data

Your information is used to:

• Set up and manage your account and deliver the Service.
• Execute trading instructions and automated orders through connected brokers.
• Personalise your experience and provide relevant market updates.
• Send essential communications such as account verifications, trade notifications, and security alerts.
• Send marketing messages when you have consented or where permitted by law.
• Detect, investigate, and prevent fraudulent or unlawful activities.
• Fulfil legal and regulatory obligations.
• Improve, test, and develop new Service features using anonymised, aggregated data.

3. Legal Bases for Processing (UK/EEA Residents)

If you are located in the UK or European Economic Area, your personal data is processed under these grounds:

• Contractual necessity: providing the Service you've agreed to.
• Legitimate interests: fraud prevention, ensuring security, and enhancing services.
• Compliance with law: meeting financial and tax regulatory requirements.
• Consent: for marketing communications and non-essential cookies, which you can revoke anytime.

4. Sharing Your Information

We never sell your personal data. We may share it with:

• Service providers: hosting, email, analytics, and customer service partners under strict confidentiality.
• Connected brokers and exchanges: only necessary API calls to execute your trading strategies.
• Legal authorities: when required by law or court order, or to protect our rights.
• Business changes: during mergers, acquisitions, or asset sales, ensuring the new entity honours this Privacy Policy.

5. International Data Transfers

TrueForge operates globally. Your data may be transferred to countries outside your residence, including the US and EU nations. We apply European Commission-approved Standard Contractual Clauses where needed to safeguard these transfers.

6. Data Retention

We keep your personal data while your account is active or as required to provide the Service. After account closure, some information may be retained for up to seven years to comply with financial laws. Anonymised, aggregated analytics data may be stored indefinitely.

7. Your Rights Regarding Your Data

Depending on your location, you may have rights to:

• Request access to your personal data.
• Correct any errors or incomplete information.
• Request deletion of your data (the "right to be forgotten").
• Object to or restrict certain processing activities.
• Receive your data in a portable, machine-readable format.
• Withdraw consent at any time without impacting prior lawful processing.

To exercise your rights, please contact us at [email protected]. We strive to respond within 30 days.

8. Security Practices

We employ industry-recognised security measures including TLS 1.3 for data in transit, AES-256 encryption at rest, multi-factor authentication, role-based permissions, and annual external penetration tests. While these precautions reduce risk, no system is entirely impervious. We recommend choosing a strong, unique password and enabling two-factor authentication.

9. Use of Cookies

Cookies and similar tools are used to support and improve the Service. For more detail, see our Cookie Policy.

10. Protection of Minors

The Service is intended solely for users aged 18 or older. We do not knowingly collect data from minors. If you believe a minor has provided us with personal data, please contact us promptly so we can remove it.

11. Updates to This Policy

We may update this Privacy Policy from time to time. Significant changes will be communicated via notices on our website or by email. Continued use after updates means you accept the revised terms.

12. Contact Information

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

• Email: [email protected]
• Postal Address: TrueForge Inc., 25 Old Broad Street, London EC2N 1HQ, United Kingdom
• EU Representative: TrueForge Europe Ltd., 12 Hanover Square, London W1S 1HN, United Kingdom