Privacy information

1. Information we collect

1.1 Details you provide

When you open an account or use the Service, we may gather the following information:

• Identity information: your first and last name and date of birth.
• Contact information: your email address, telephone number, and home address.
• Financial information: Broker API keys with read and execution permissions, investment preferences, and risk settings. We do not retain complete broker login details or payment-card numbers.
• Account profile information: your username, strategy preferences, and notification choices.
• Communications: messages submitted through support channels or sent by email.

1.2 Data gathered automatically

While you use the Service, certain technical details may be collected automatically:

• IP address, browser and browser-version information, and operating system.
• Visited pages, features accessed, time on site, and clickstream activity.
• Device identifiers and mobile advertising identifiers where relevant.
• Information about cookies and tracking tools (see our Cookie Policy).

1.3 Information supplied by third parties

We may obtain information from identity-check providers, fraud-prevention services, and analytics partners. We may combine that information with existing records to improve accuracy and protection.

2. How we use information

The information we collect may be used to:

• Set up and administer your account and deliver the Service.
• Handle trading signals and automated orders through connected brokers.
• Tailor your experience and show relevant market information.
• Send service messages, including confirmations, trading notices, and security alerts.
• Provide marketing messages when you consent or applicable law allows it.
• Identify, examine, and stop fraudulent or improper activity.
• Meet legal and regulatory requirements.
• Test, improve, and build Service features using aggregated and anonymised information.

3. Processing grounds for EEA and UK users

If you are in the European Economic Area or the United Kingdom, we process personal information on the following bases:

• Performance of a contract: to deliver the Service you requested.
• Legitimate interests: fraud prevention, security, and product development.
• Legal requirement: meeting financial-regulation and tax obligations.
• Consent: marketing messages and optional cookies, which you may withdraw at any time.

4. When we share information

We do not sell personal information. We may disclose it to:

• Service providers: cloud-hosting, email, analytics, and customer-support providers bound by contractual data-protection duties.
• Connected brokers and exchanges: only the API instructions needed to carry out your selected strategy.
• Authorities: where required by law or court order, or where needed to protect our rights.
• Business transfers: as part of a merger, acquisition, or asset transaction, provided the recipient continues to respect this policy.

5. Transfers of information internationally

European Consumer Refund serves users internationally. Information may be moved to and processed in jurisdictions outside your home country, including the United States and European Union member states. Where applicable, we rely on European Commission-approved Standard Contractual Clauses for international transfers.

6. How long we keep data

We keep personal information while your account remains open or for as long as needed to provide the Service. Following closure, some records may be retained for up to seven years to meet financial-regulatory requirements. Aggregated, anonymised analytics may be kept without a fixed end date.

7. Your rights

Subject to your location, you may have the right to:

• Obtain a copy of the personal information we hold about you.
• Ask us to correct incomplete or inaccurate information.
• Ask for your information to be erased (the “right to be forgotten”).
• Challenge or limit particular processing activities.
• Data portability: receive your information in a structured, machine-readable form.
• Withdraw consent at any time, without changing the lawfulness of earlier processing.

To make a rights request, contact us at [email protected]. We aim to reply within 30 days.

8. Security safeguards

We use recognised security controls, including TLS 1.3 for data in transit, AES-256 for stored data, multi-factor authentication, role-based permissions, and yearly independent penetration tests. No system can be guaranteed completely secure. Please choose a strong, unique password and activate two-factor authentication.

9. Cookies and similar tools

Cookies and related technologies help us operate and enhance the Service. For more information, consult our Cookie Policy.

10. Privacy of children

The Service is intended for people aged 18 or over. We do not knowingly gather information from minors. If you think a minor has supplied personal information, tell us and we will take steps to remove it promptly.

11. Updates to this policy

This Privacy Policy may change periodically. We will communicate significant updates through a website notice or email. Continuing to use the Service after an update takes effect means you accept the revised policy.

12. How to contact us

For privacy questions or to use your rights, contact our Data Protection Officer:

• Email address: [email protected]
• Postal address: European Consumer Refund Inc. — 200 Park Avenue, New York, NY 10166, United StatesUnited States
• EU representative: European Consumer Refund, 200 Park Avenue, New York, NY 10166, United States