Privacy Policy

1. Introduction & Contact Information

Company Information:
TradeVae, LLC
1000 North West Street Mid-Town Brandy Wine, Suite 1200, Wilmington, DE 19801
United States

Contact Us:
For privacy-related inquiries, data protection requests, or questions about this Privacy Policy, please contact us at:
Email: support@tradevae.com
Website: https://mail.tradevae.com/contact/

Scope: This Privacy Policy applies to all information collected through our Platform, including information collected online, through our mobile applications, via email, or through any other means. This policy does not apply to information collected by third-party websites, services, or applications that you may access through our Platform.

2. Information We Collect

We collect information that you provide directly to us, information that is automatically collected when you use our Platform, and information from third-party sources. The types of information we collect include:

2.1 Personal Information You Provide

Account Registration:

• Email address (required)
• First name and last name (required)
• Password (encrypted and stored securely)
• Registration date and timestamp

Profile Information (Optional):

• Display name
• Region and country
• Avatar or profile picture
• Bio or personal description

Subscription and Payment Information:

• Subscription plan selection
• Payment information (processed securely through Stripe - we do not store full credit card details)
• Stripe customer ID and subscription ID
• Subscription status, start date, and end date
• Billing history and transaction records

User-Generated Content:

• Portfolio data (tickers, positions, entry prices, position sizes, position types)
• Watchlist data (tickers you track)
• AI chat conversations and interactions
• Saved screeners and custom search criteria
• Tool calculations (position size, risk-reward calculations)

Communications:

• Contact form submissions (name, email, subject, message)
• Support requests and customer service communications
• Feedback, comments, or survey responses

2.2 Automatically Collected Information

When you access or use our Platform, we automatically collect certain information, including:

• Device Information: Device type, operating system, browser type and version, screen resolution, and device identifiers
• Log Data: IP address, access times, pages viewed, links clicked, search queries, and referring website addresses
• Usage Information: Features used, time spent on pages, click patterns, navigation paths, and interaction data
• Location Information: General geographic location derived from IP address (country/region level, not precise location)
• Authentication Data: Last login date and time, last login IP address, session identifiers
• Cookies and Similar Technologies: See Section 6 for detailed information about cookies and tracking technologies

2.3 Information from Third-Party Sources

We may receive information about you from third-party sources, including:

• Payment Processors: Stripe provides us with payment status, transaction IDs, and billing information necessary to process subscriptions
• Market Data Providers: We integrate with Polygon.io, Finnhub, and Alpha Vantage to provide market data, but we do not share your personal information with these providers
• Authentication Services: If you choose to authenticate through third-party services (if available), we may receive basic profile information

3. How We Use Your Information

We use the information we collect for various purposes, including:

• Service Provision: To provide, maintain, operate, and improve our Platform and services, including AI-powered analysis, stock screening, portfolio tracking, and market insights
• Account Management: To create and manage your account, authenticate your identity, and provide access to Platform features
• Payment Processing: To process subscription payments, manage billing, send payment confirmations, and handle refunds (where applicable)
• Communication: To send you transactional emails (account verification, password resets, subscription confirmations), respond to your inquiries, and provide customer support
• Personalization: To personalize your experience, customize content and features, and remember your preferences
• AI Services: To generate AI-powered insights, analysis, predictions, and recommendations based on your usage patterns and market data
• Platform Improvement: To analyze usage patterns, identify trends, improve functionality, develop new features, and enhance user experience
• Security and Fraud Prevention: To detect, prevent, and address security issues, fraudulent activity, unauthorized access, and other illegal activities
• Legal Compliance: To comply with applicable laws, regulations, legal processes, court orders, and government requests
• Enforcement: To enforce our Terms of Use, protect our rights and property, and protect the rights and safety of our users and third parties
• Analytics: To conduct analytics, measure Platform performance, understand user behavior, and generate aggregated, anonymized statistics
• Marketing: With your consent, to send you marketing communications about new features, services, or promotions (you may opt-out at any time)

4. Legal Basis for Processing (GDPR)

If you are located in the European Economic Area (EEA) or United Kingdom (UK), we process your personal information under the following legal bases:

• Contractual Necessity: To perform our contract with you (providing Platform services, processing payments, managing your account)
• Legitimate Interests: To improve our Platform, prevent fraud, ensure security, analyze usage patterns, and communicate important service updates (we balance our interests against your privacy rights)
• Consent: Where you have provided explicit consent (e.g., marketing communications, optional profile information, cookies requiring consent)
• Legal Obligations: To comply with applicable laws, regulations, and legal requirements (e.g., tax reporting, fraud prevention, data retention requirements)

You have the right to object to processing based on legitimate interests. See Section 9 for information about your rights and how to exercise them.

5. Information Sharing & Disclosure

We do not sell, rent, or trade your personal information. We may share your information only in the following circumstances:

5.1 Third-Party Service Providers

We share information with trusted third-party service providers who assist us in operating our Platform, conducting our business, and serving our users. These providers are contractually obligated to protect your information and use it only for the purposes we specify:

• Payment Processing: Stripe processes payments and handles billing. Stripe is PCI-DSS compliant and does not share your payment information with us beyond what is necessary for transaction processing.
• AI Services: OpenAI processes data to generate AI-powered insights, analysis, and content. We have data processing agreements in place with OpenAI that require appropriate safeguards for your data.
• Market Data Providers: We use Polygon.io, Finnhub, and Alpha Vantage for market data. We do not share your personal information with these providers; they provide us with publicly available market data only.
• Email Services: We use SMTP email services to send transactional and marketing emails. Email providers process email delivery but do not use your information for their own purposes.
• Hosting and Infrastructure: Our servers and databases are hosted by third-party cloud providers who maintain appropriate security measures.
• Analytics Providers: We may use analytics services to understand Platform usage and performance. These services may collect anonymized usage data.
• Chart Services: TradingView provides chart widgets embedded in our Platform. TradingView may collect usage data related to chart interactions.

5.2 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities, including:

• Court orders, subpoenas, or other legal processes
• Law enforcement requests
• Regulatory compliance requirements
• Government investigations
• Protection of rights, property, or safety

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of assets, your information may be transferred to the acquiring entity. We will notify you of any such change in ownership or control of your personal information.

5.4 With Your Consent

We may share your information with third parties when you have provided explicit consent for such sharing.

6. Cookies & Tracking Technologies

We use cookies, web beacons, and similar tracking technologies to collect and store information about your use of our Platform.

6.1 Types of Cookies We Use

Essential Cookies: Required for the Platform to function properly. These include session cookies for authentication, security cookies, and cookies that remember your preferences. These cookies cannot be disabled.

Functional Cookies: Enhance functionality and personalization, such as remembering your language preferences or display settings.

Analytics Cookies: Help us understand how visitors interact with our Platform by collecting and reporting information anonymously.

Third-Party Cookies: Set by third-party services embedded in our Platform, such as TradingView charts. These cookies are subject to the third party's privacy policy.

6.2 Cookie Management

Most web browsers allow you to control cookies through their settings. You can set your browser to refuse cookies or alert you when cookies are being sent. However, disabling cookies may limit your ability to use certain features of our Platform.

Do Not Track: Our Platform does not currently respond to "Do Not Track" signals from browsers. However, you can control cookie preferences through your browser settings.

7. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption: Passwords are hashed using bcrypt. Sensitive data is encrypted in transit using TLS/SSL and at rest where appropriate.
• Secure Transmission: All data transmitted between your device and our servers is encrypted using HTTPS/TLS protocols.
• Access Controls: We limit access to personal information to authorized employees, contractors, and service providers who need such access to perform their duties.
• Regular Security Assessments: We conduct regular security assessments, vulnerability testing, and security audits.
• Incident Response: We have procedures in place to detect, respond to, and mitigate security incidents.
• Data Minimization: We collect and retain only the information necessary for our business purposes.

No Absolute Security: While we strive to protect your information, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security of your information. You use the Platform at your own risk.

Account Security: You are responsible for maintaining the confidentiality of your account credentials. Please use a strong, unique password and do not share your account information with others.

8. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

• Account Data: We retain your account information while your account is active and for a reasonable period after account closure (typically 30-90 days) to comply with legal obligations, resolve disputes, and enforce our agreements.
• Transaction Records: Payment and subscription records are retained as required by law (typically 7 years for tax and accounting purposes).
• Usage Data: Analytics and usage data may be retained in aggregated, anonymized form indefinitely for business analysis purposes.
• Logs: Server logs and security logs are typically retained for 90 days to 1 year, depending on the type of log and legal requirements.
• User Content: Portfolio data, watchlists, and other user-generated content are retained until you delete them or close your account.

Deletion: Upon account closure or upon your request (subject to legal requirements), we will delete or anonymize your personal information. Some information may be retained if required by law or for legitimate business purposes (e.g., fraud prevention, legal disputes).

Legal Holds: We may retain information beyond our normal retention period if required by law, court order, or ongoing legal proceedings.

9. Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information. This section describes your rights and how to exercise them.

9.1 Access and Portability Rights

• Right to Know: You have the right to know what personal information we collect, use, disclose, and sell (if applicable).
• Right to Access: You have the right to request access to your personal information and receive a copy of the data we hold about you.
• Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that data to another service provider (where technically feasible).

9.2 Control and Correction Rights

• Right to Rectification: You have the right to request correction of inaccurate or incomplete personal information.
• Right to Erasure (Right to Delete): You have the right to request deletion of your personal information, subject to certain exceptions (e.g., legal obligations, ongoing disputes).
• Right to Restrict Processing: You have the right to request that we restrict the processing of your personal information in certain circumstances.
• Right to Object: You have the right to object to processing of your personal information based on legitimate interests or for direct marketing purposes.

9.3 How to Exercise Your Rights

To exercise any of these rights, please contact us at support@tradevae.com with the subject line "Privacy Request" and include:

• Your full name and email address associated with your account
• A clear description of the right you wish to exercise
• Any additional information necessary to process your request

Verification: For security purposes, we may need to verify your identity before processing your request. We may ask you to provide additional information or confirm your identity through your account.

Response Time: We will respond to your request within 30-45 days, depending on the complexity of the request and applicable law. If we need more time, we will notify you.

No Discrimination: We will not discriminate against you for exercising your privacy rights. However, certain features may require personal information to function, and we may not be able to provide services if you request deletion of necessary information.

10. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

10.1 Categories of Personal Information Collected

In the past 12 months, we have collected the following categories of personal information:

• Identifiers: Name, email address, IP address, device identifiers
• Personal Information: Name, contact information, payment information
• Protected Classification Characteristics: None (we do not collect information about race, gender, etc.)
• Commercial Information: Subscription history, purchase records, transaction data
• Internet Activity: Browsing history, search history, interaction data, usage patterns
• Geolocation Data: General location derived from IP address (country/region level)
• Professional Information: None (unless provided in profile)
• Inferences: Preferences, characteristics, behavior patterns derived from usage data

10.2 Sources of Personal Information

• Directly from you (registration, profile, communications)
• Automatically from your use of the Platform (usage data, device information)
• Third-party service providers (payment processors, market data providers)

10.3 Business Purposes for Collection

We collect personal information for the business purposes described in Section 3, including service provision, payment processing, platform improvement, security, legal compliance, and analytics.

10.4 Third-Party Sharing

We share personal information with third-party service providers as described in Section 5.1. We do not sell personal information to third parties.

10.5 Authorized Agent

California residents may designate an authorized agent to submit privacy requests on their behalf. Authorized agents must provide proof of authorization and verify their identity. Contact us at support@tradevae.com for instructions on submitting requests through an authorized agent.

10.6 California Shine the Light Act

California residents may request information about our disclosure of personal information to third parties for their direct marketing purposes. We do not share personal information with third parties for their direct marketing purposes.

11. European Privacy Rights (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, you have additional rights under the General Data Protection Regulation (GDPR):

11.1 Data Controller

TradeVae, LLC is the data controller for your personal information. Our contact information is provided in Section 1.

11.2 Your GDPR Rights

In addition to the rights described in Section 9, you have the following rights under GDPR:

• Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before withdrawal.
• Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority in your country of residence if you believe we have violated your privacy rights.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller (where technically feasible).

11.3 Supervisory Authorities

If you are located in the EEA, UK, or Switzerland, you can find your local supervisory authority at:

• EEA: European Data Protection Board
• UK: Information Commissioner's Office (ICO)
• Switzerland: Federal Data Protection and Information Commissioner (FDPIC)

12. Do Not Sell My Personal Information (CCPA)

We Do Not Sell Personal Information: TradeVae does not sell, rent, or trade your personal information to third parties for monetary or other valuable consideration.

We share personal information with third-party service providers as described in Section 5.1, but these arrangements are for business purposes (service provision) and do not constitute "sales" under CCPA.

If our practices change in the future and we begin selling personal information, we will update this Privacy Policy and provide you with an opt-out mechanism.

13. Children's Privacy (COPPA)

Our Platform is not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18 years of age.

If you are a parent or guardian and believe your child under 18 has provided us with personal information, please contact us immediately at support@tradevae.com. We will delete such information promptly upon verification.

If we learn that we have collected personal information from a child under 18 without parental consent, we will take steps to delete that information as soon as possible, in accordance with the Children's Online Privacy Protection Act (COPPA).

14. International Data Transfers

Data Location: Your personal information is primarily processed and stored on servers located in the United States. If you are located outside the United States, your information will be transferred to, stored, and processed in the United States.

Third-Party Transfers: Some of our third-party service providers may process your information in countries outside your country of residence. These transfers are necessary to provide our services.

GDPR Safeguards: For transfers from the EEA, UK, or Switzerland to the United States, we rely on appropriate safeguards, including:

• Standard Contractual Clauses approved by the European Commission
• Data processing agreements with service providers
• Other legally recognized transfer mechanisms

By using our Platform, you consent to the transfer of your information to the United States and other countries where our service providers operate.

15. Marketing Communications

Transactional vs. Marketing: We send two types of emails:

• Transactional Emails: Account verification, password resets, subscription confirmations, and important service updates. These are necessary for account management and cannot be opted out of.
• Marketing Emails: Newsletters, promotional offers, feature announcements, and other marketing communications. These require your consent and can be opted out of at any time.

Opt-Out: You can opt-out of marketing communications by:

• Clicking the "unsubscribe" link in any marketing email
• Updating your email preferences in your account settings
• Contacting us at support@tradevae.com

Please note that opting out of marketing communications does not affect transactional emails necessary for account management.

16. Third-Party Links & Services

Our Platform may contain links to third-party websites, services, or applications that are not owned or controlled by TradeVae. We are not responsible for the privacy practices of these third parties.

Third-Party Services Integrated in Our Platform:

• TradingView: Chart widgets embedded in our Platform. TradingView's privacy policy applies to data collected through their widgets: TradingView Privacy Policy
• Stripe: Payment processing. Stripe's privacy policy applies to payment data: Stripe Privacy Policy
• OpenAI: AI services. OpenAI's privacy policy applies to data processed through their services: OpenAI Privacy Policy

We encourage you to review the privacy policies of any third-party websites or services you access through our Platform. This Privacy Policy does not apply to information collected by third parties.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:

• Posting the updated Privacy Policy on this page with a new "Last Updated" date
• Sending an email notification to the email address associated with your account (for material changes)
• Displaying a prominent notice on our Platform (for significant changes)

Continued Use: Your continued use of our Platform after any changes to this Privacy Policy constitutes your acceptance of the updated policy. If you do not agree with the changes, you should stop using the Platform and may close your account.

Review Policy: We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your information.

18. Data Breach Notification

In the event of a data breach that compromises your personal information, we will:

• Investigate Promptly: Immediately investigate the breach, assess the scope and impact, and take steps to contain and remediate the breach.
• Notify Regulators: Notify relevant supervisory authorities within 72 hours (as required by GDPR) or as otherwise required by applicable law.
• Notify Affected Users: Notify affected users without undue delay if the breach is likely to result in a high risk to their rights and freedoms. Notification will be sent to the email address associated with your account.
• Provide Information: Include in the notification: description of the breach, categories of data affected, likely consequences, and measures taken or proposed to address the breach.

We maintain incident response procedures and regularly review and update our security measures to prevent breaches.

19. Additional State-Specific Disclosures

Delaware State Law: As a Delaware limited liability company, we comply with applicable Delaware state laws regarding data protection and privacy.

Other State Privacy Laws: We comply with applicable state privacy laws, including but not limited to:

• California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)
• Virginia Consumer Data Protection Act (VCDPA)
• Colorado Privacy Act (CPA)
• Connecticut Data Privacy Act (CTDPA)
• Utah Consumer Privacy Act (UCPA)
• Other state privacy laws as they become effective

If you are a resident of a state with specific privacy laws, you may have additional rights. Please refer to the relevant sections of this Privacy Policy or contact us for more information.

20. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Email: support@tradevae.com
Subject Line: "Privacy Inquiry" or "Privacy Request"
Website: https://mail.tradevae.com/contact/

Physical Address for Legal Notices:
TradeVae, LLC
1000 North West Street Mid-Town Brandy Wine, Suite 1200, Wilmington, DE 19801
United States

Response Time: We aim to respond to all privacy inquiries within 30-45 days, as required by applicable law.