Privacy statement

1. Information collected

1.1 Details you provide

When you create an account or use the Service, we may collect the following categories of information:

• Identity details: your given name, family name and date of birth.
• Contact details: your email, phone number and residential address.
• Financial details: Broker API credentials limited to reading and execution, along with investment selections and risk preferences. We do not store full broker passwords or complete card numbers.
• Profile information: your user ID, chosen strategies and notification preferences.
• Communications: messages you send through support channels or email.

1.2 Data collected automatically

Your use of the Service may generate technical information automatically, such as:

• IP address, browser name and version, and operating system information.
• Pages viewed, features used, time spent and clickstream data.
• Device identifiers and, when applicable, mobile advertising identifiers.
• Cookie and tracking information (see our Cookie Policy).

1.3 Information received from third parties

Identity verification providers, fraud-screening services and analytics partners may share information with us. We may compare that data with information already held to improve accuracy and security.

2. Uses of information

We may use collected information to:

• Create, operate and maintain your account and provide the Service.
• Process trading signals and automated orders through linked brokers.
• Personalise your experience and show pertinent market information.
• Send service communications, including confirmations, trading notices and security alerts.
• Send marketing communications where you consent or the law permits.
• Detect, investigate and help prevent fraud or unauthorised access.
• Comply with applicable legal and regulatory duties.
• Improve, test and develop Service features using aggregated, anonymised data.

3. Legal bases for people in the EEA and UK

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

• Performance of a contract: to deliver the Service you requested.
• Legitimate interests: to protect the Service, reduce fraud and improve our offering.
• Legal obligation: to satisfy financial and tax requirements.
• Consent: for marketing and optional cookies, which you can withdraw at any time.

4. Information sharing

We do not sell personal information. We may share it with:

• Service providers: cloud, email, analytics and support suppliers contractually required to protect your information.
• Linked brokers and exchanges: only the API directions needed to execute the strategy you chose.
• Government and public bodies: when required by law or court order, or when disclosure is necessary to protect our legal interests.
• Corporate transactions: as part of a merger, acquisition or transfer of assets, provided the successor continues to follow this Policy.

5. International data transfers

Trustaris Inc. conducts business internationally. Your personal information may be moved to and processed in jurisdictions outside your province or country of residence, including the United States and European Union member states. Where required, international transfers rely on Standard Contractual Clauses adopted by the European Commission.

6. Data retention

We retain personal information while your account is active and for as long as necessary to deliver the Service. Once the account closes, certain records may remain for up to seven years to satisfy financial and regulatory obligations. Aggregated and anonymised analytics may be kept indefinitely.

7. Choices available to you

Depending on where you live, you may be entitled to:

• Obtain a copy of the personal information we maintain about you.
• Have inaccurate or incomplete details corrected.
• Ask for your information to be erased where no legal exception prevents it (the “right to be forgotten”).
• Object to certain processing activities or request limits on how your information is handled.
• Data portability — obtain your personal information in a structured, widely used, machine-readable format.
• Revoke consent at any time; doing so does not invalidate processing carried out lawfully before withdrawal.

To make one of these requests, contact us at [email protected]. We normally reply within 30 days.

8. Protecting information

Our safeguards include TLS 1.3 for information in transit, AES-256 encryption for stored data, multi-factor authentication, role-based access and annual independent penetration testing. No system can be guaranteed completely secure. Choose a strong, unique password and enable two-factor authentication.

9. Cookies and similar technologies

Cookies and related technologies support the operation and improvement of the Service. More details can be found in our Cookie Policy.

10. Children’s privacy

The Service is for individuals aged 18 and over. We do not knowingly gather personal information from minors. If you believe a minor has provided us with data, please tell us so we can take reasonable steps to remove it without undue delay.

11. Changes to this policy

We may revise this Privacy Policy from time to time. Significant changes will be posted online or communicated by email. Using the Service after an amended policy becomes effective indicates acceptance of the updated terms.

12. How to contact us

For privacy enquiries or requests relating to your rights, contact our Data Protection Officer:

• Email: [email protected]
• Mailing address: Trustaris Inc. 200 Park Avenue, New York, NY 10166, United States, United States
• EU representative: Trustaris, 200 Park Avenue, New York, NY 10166, United States