Privacy Policy

Date of last revision: September 19, 2025

1. Introduction
Introduction At Tradeflow ("we", "us", or "our"), we are committed to protecting and respecting your privacy. This Privacy Policy sets forth how we collect, use, disclose, and protect personal data in connection with your use of our platform and services. Tradeflow provides an online environment where users can connect trading accounts, analyze their trading performance, participate in competitions, and optionally publish performance metrics.

This Privacy Policy has been prepared in accordance with, and seeks to ensure compliance with, the following data protection regulations:
• Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation - GDPR)
• The United Kingdom General Data Protection Regulation (UK GDPR)
• The California Consumer Privacy Act (CCPA)
• Brazil’s General Data Protection Law (Lei Geral de Proteção de Dados - LGPD).
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2. Who Are We?
‍Tradeflow is a trading analytics and publication platform operated by [Company Name], a legal entity registered under the laws of [Insert Jurisdiction], with its principal place of business at [Company Address], and registration number [Insert Number].

We offer a platform that enables users to connect third-party broker accounts for the purpose of tracking and optionally publishing trading performance through a secure, encrypted, read-only interface.

3. Information Collection and Use

a. Account Information
• First and last name
• Username and email address
• Password (encrypted and salted)
• Country of residence
• Language preference
• Optional profile image

b. Technical and Device Information
• IP address and device geolocation
• Browser type and version
• Operating system and device identifiers
• Access times and session metadata
• Device fingerprinting data where applicable

c. Trading and Broker Data
• Broker platform and trading account identifiers (read-only access)
• Historical and real-time trade data including balances, positions, equity, margin, drawdowns, leverage, and trade outcomes
• Connection logs related to broker account integrations

d. Community and Publication Data (User-Controlled)
• Leaderboard rankings and public profile data
• Shared trading history or metrics voluntarily published
• Signal status or strategy descriptions (where applicable and opted-in)

e. Communications and Feedback Data
• Customer service inquiries, feedback messages, and survey responses
• Participation in discussion boards or private correspondence

f. Cookie and Analytics Data
• See Section 11 for a detailed overview of our use of cookies and tracking technologies.

4. How We Use Your Data
We process your personal data exclusively for the purposes defined below:
• To create and manage your user account
• To connect broker data and display performance analytics securely
• To deliver personalized dashboard features and performance summaries
• To facilitate your participation in optional leaderboard rankings or competitions
• To comply with legal and regulatory requirements
• To detect, prevent, and respond to security threats, abuse, or fraud
• To enhance user experience and optimize system performance
• To send service-related notifications or communications

Anonymized and aggregated performance data may also be used for statistical purposes, research, or commercial insights, provided such use does not identify individual users.

We do not send promotional content or newsletters without your explicit consent, and you may unsubscribe at any time via your account preferences.

5. Legal Bases for Processing
We process your data on the following legal grounds:
• Your consent, where applicable (e.g., for marketing, cookies, leaderboard publication)
• Contractual necessity (e.g., providing core platform services)
• Legal obligations (e.g., fraud prevention or compliance)
• Legitimate interests (e.g., to improve platform security and usability)

6. Sharing and Disclosure of Data
Tradeflow does not sell your personal data. We only share it with third parties when necessary for service provision, legal compliance, or system performance, including:

7. Data Retention
We retain your data for no longer than is necessary:
• For the duration your account remains active
• Up to 12 months after voluntary account deletion (for regulatory and audit purposes)
• Longer if required by applicable financial, tax, or legal regulations
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8. Security Measures
We implement appropriate technical and organizational security measures to safeguard your personal data, including:
• Full HTTPS encryption throughout the platform
• Encrypted storage of user credentials and broker API keys
• Multi-factor authentication for user accounts (optional but recommended)
• Role-based access controls for staff and administrators
• Periodic penetration testing and security assessments
• Secure data hosting via ISO-certified providers

9. Your Data Protection Rights
Depending on your jurisdiction, you may have rights under GDPR, CCPA, LGPD or equivalent laws, including:
• Right to access your personal data
• Right to correct or delete inaccurate information
• Right to object to or restrict certain types of processing
•Right to withdraw consent at any time (without affecting prior processing)
• Right to receive your data in a portable format
• Right to lodge a complaint with a supervisory authority

To exercise any of these rights, please contact us via info@tradeflow.so. We aim to respond within 30 calendar days.

10. Public Leaderboards and Profile Publication (Optional Feature)
If you voluntarily opt to participate in public competitions or leaderboards, the following data may be displayed:
• Username, performance history, and strategy metrics
• Public ranking and signal sharing status (if enabled)
• Broker name (display-only, never with credentials)

You may opt-out of public visibility at any time. Aliases may be used in lieu of real names or profile images. We are not responsible for third-party redistribution of voluntarily published data.

11. Cookies and Tracking Technologies
We use cookies and related technologies for the following purposes:

a. Categories of Cookies
• Essential cookies: for secure login and account session management
• Functional cookies: for saving settings and user preferences
• Analytical cookies: for platform usage insights (e.g., via Google Analytics, Mixpanel)
• Marketing cookies: only used with prior consent

b. Third Party Integrations
Some cookies may originate from third-party content providers (e.g., YouTube, Stripe). These providers may independently process your data under their own privacy terms.
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c. User Control
You may manage cookie preferences via the cookie banner on first visit or through your browser settings. Non-essential cookies are only activated after explicit consent.

12. International Data Transfers 
If personal data is transferred outside of the European Economic Area (EEA), such transfers will be safeguarded by:
• Standard Contractual Clauses (SCCs)
• European Commission adequacy decisions
• Technical measures such as data encryption and pseudonymization
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13. Children’s Privacy
Tradeflow is not directed at individuals under the age of 18. We do not knowingly collect or process personal data of minors. If we become aware of such data, it will be deleted without undue delay.

14. Policy Amendements
We may periodically revise this Privacy Policy to reflect changes in our operations or legal obligations. We will notify users of material changes via email or in-platform notifications. Continued use of the platform following such updates constitutes acceptance of the revised policy.

In the event of a corporate acquisition, merger, or restructuring, user data may be transferred to a successor entity. Users will be informed and provided with the ability to opt out where legally applicable.

15. Broker Account Permissions
Broker account connections are exclusively read-only. Tradeflow does not and cannot execute trades, manage funds, or modify user positions in any capacity. All account access occurs via encrypted API connections initiated by the user.

Broker credentials with trading rights are neither stored nor requested by Tradeflow. Users retain full control over their trading accounts at all times.

16. Competition and Leaderboard Data
Participation in competitions is entirely optional. By joining, users consent to the collection and display of relevant performance metrics such as equity, returns, drawdowns, and trading history.

Users may participate using an alias and may revoke public participation at any time. Aggregated data from competitions may be used for promotional content, statistical insights, or performance benchmarks.

17. Capital Risk Disclaimer
Capital Risk Disclaimer Trading in financial instruments involves a high degree of risk and is not suitable for all investors. You may incur substantial losses, including the total loss of your capital. By using Tradeflow, you acknowledge that you are solely responsible for your trading decisions and that Tradeflow bears no liability for any trading-related losses, regardless of how such losses occur, including losses incurred via competitions, data visualization, or public rankings.

18. Third-Party Broker Disclaimer
Third-Party Broker Disclaimer Tradeflow operates independently and is not affiliated with any brokerage service. Any issues, delays, service interruptions, or transactional errors originating from third-party brokers must be resolved directly with those entities.

We do not guarantee the accuracy or availability of third-party broker data and disclaim all responsibility for losses arising from broker-side issues.

19. Automated Decision-Making and Profiling
Tradeflow does not make decisions that have legal or similarly significant effects on users based solely on automated processing or profiling, in accordance with Article 22 of the GDPR.

20. Transparency Commitment
We believe transparency is essential to trust. All opt-in features, data-sharing permissions, and account visibility settings are fully user-controlled. You may update or revoke these permissions at any time through your account dashboard.

21. Use of Data for Marketing and Promotion 
With your explicit consent, Tradeflow may use anonymized or publicly shared performance data for promotional purposes, such as leaderboards, case studies, testimonials, or marketing campaigns. Identifiable data such as names or profile photos will only be used with written authorization.
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22. No Financial Advice or Responsibility for Losses
Tradeflow is not a financial institution, advisor, or portfolio manager. We do not provide investment recommendations, portfolio strategies, or personalized trading advice. All content and data are provided for informational purposes only.

You understand and agree that all trading activity involves risk and that Tradeflow is not liable for any direct or indirect financial losses incurred as a result of using our platform.

23. Third-Party Broker Relationship
Tradeflow is not endorsed by or partnered with any broker. We provide access to performance tracking via user-authorized, read-only integrations. All issues related to account access, trade execution, or data delays must be addressed with the relevant broker directly.