Privacy Policy

1. Important context

Non-custodial trading. We do not custody your trading funds or digital assets. Your balances remain with third-party exchanges or brokers. We process information needed to operate the Service, including API connectivity and account authentication.

2. Information we collect

Depending on how you use the Service, we may collect:

• Account and contact data: email address, name or username, and authentication identifiers (e.g., for login or OTP verification).
• Technical data: IP address, device type, browser, approximate location derived from IP, logs, timestamps, and diagnostic information for security and reliability.
• API and integration data: exchange or broker identifiers, API key metadata (we strongly encourage permission-scoped keys), connection status, and operational logs related to order routing or automation—only as needed to provide the Service you configure.
• Usage data: feature usage, subscription tier, support interactions, and communications you send to us.
• Billing data: processed by payment processors; we typically receive limited billing confirmation rather than full card numbers.

3. How we use information

We use personal information to:

• Provide, operate, and improve the Service, including API-linked execution features;
• Authenticate users and prevent fraud, abuse, and security incidents;
• Communicate about your account, updates, and important notices;
• Comply with legal obligations and enforce our terms;
• Analyze aggregated or de-identified usage to improve product performance.

4. Legal bases (where applicable)

Where GDPR or similar laws apply, we rely on bases such as: performance of a contract, legitimate interests (security, analytics, product improvement—balanced against your rights), consent where required (e.g., certain cookies or marketing), and legal obligation.

5. Sharing and subprocessors

We may share information with service providers who assist us (hosting, analytics, email delivery, payment processing, customer support), subject to contractual safeguards. We may disclose information if required by law, to protect rights and safety, or in connection with a merger or asset transfer. We do not sell your personal information as “sale” is commonly understood under U.S. state privacy laws, except as disclosed and permitted when you opt in where required.

6. International transfers

If you access the Service from outside our primary operating region, your information may be processed in countries with different data-protection laws. We implement appropriate safeguards where required (e.g., standard contractual clauses).

7. Retention

We retain personal information as long as necessary to provide the Service, comply with law, resolve disputes, and enforce agreements. Technical logs may be retained for shorter or longer periods based on security and operational needs.

8. Security

We use administrative, technical, and organizational measures designed to protect personal information. No method of transmission or storage is completely secure; you use the Service at your own risk beyond our reasonable safeguards.

9. Your rights

Depending on your location, you may have rights to access, correct, delete, or port your personal information, object to or restrict certain processing, withdraw consent where processing is consent-based, and lodge a complaint with a supervisory authority. Contact us to exercise rights; we will respond as required by law.

10. Children

The Service is not directed to individuals under the age required to enter a binding contract in their jurisdiction. We do not knowingly collect personal information from children.

11. Changes to this policy

We may update this Privacy Policy from time to time. We will post the revised policy and update the “Last updated” date. Material changes may require additional notice where required by law.

12. Contact

For privacy inquiries or requests, contact us through the contact information provided on the TradeICT Earner website.